Surviving a Meaningful Use audit, no doubt, is a difficult task, so much so that the American Academy of Family Physicians earlier this month implored Acting Center for Medicare & Medicaid Services Administrator Andy Slavitt for relief from the process.
At the Healthcare Information and Management Systems Society's annual conference in Chicago last week, Cathy Borst, vice president and CIO at Chicago-based National Surgical Healthcare, and consultant Patty Guinn, of Atlanta-based Cornerstone Advisors, outlined best practices for surviving an audit request.
"When you get an audit notification, what was already formidable [preparing in case of an audit] feels daunting and stressful," Guinn said. "I don't know of any organizations that have come out and said 'well, we've got this.'"
Added Borst: "I was coloring my hair every two weeks regularly before the audit. It became a weekly practice when I received the audit request."
To that end, Borst and Guinn shared six steps providers should take from the inception of Meaningful Use through an audit. Those steps include:
- Understand the Meaningful Use evidentiary requirements: "We saved everything," Borst said. "We wanted it to be clear that we were doing our part to prepare for an audit."
- Define and validate the required reports
- Run and validate those reports
- Compile the book of evidence using an audit prep tool: Doing this at the time of attestation ensures data will be current and valid, Borst said.
- Perform a mock audit
- Prepare and submit a response
"The number of audits is on the rise," Guinn said. "[The Centers for Medicare & Medicaid Services] says they project their audit rate around 5 percent for facilities that have attested, and Figliozzi and Co. says that there's a 4.7 percent failure rate for first time audits."
"Most experts say it's a matter of when, not if, an audit notification will be received," she added.
About 22 percent of eligible professionals have failed the audits, a much higher failure rate than that for hospitals. Meaningful Use audits can be particularly daunting because CMS has issued little guidance about the audit appeals process. To make matters worse, the Office of Inspector General has separately begun to Meaningful Use audits of providers.