By Marla Durben Hirsch
The providers selected for a Meaningful Use audit theoretically are chosen at random. However, they're not completely accidental; auditors keep an eye out for certain "red flags" that may trigger an audit, warns Ed Koschka (pictured), IT Program Manager, Meaningful Use and Accountable Care Organization Programs for Franciscan Alliance, a health system based in Mishawaka, Indiana. His healthcare system, which includes 12 hospitals and 500 physicians, has been subject to three hospital Meaningful Use audits, five professional Medicare Meaningful Use audits and two Medicaid Meaningful Use audits. (The system has passed all of them so far; one of the Medicaid audits is still pending).
Some of the red flags that the auditors are looking for include:
- Inconsistences within the provider's own data, such as exclusions that may be inconsistent with other measures a provider is attesting to or discrepancies with numerators and denominators
- Certain EHR systems which are known for having functionality problems and which may make their users more likely to be audited, warns David Zavala, senior manager with consulting firm Protiviti in Dallas
- Years where scores are combined, say while transitioning from one EHR to another, midyear
- Attestation data that is inconsistent with CMS supplemental data, such as measures or exclusions inconsistent with the provider's patient mix or inconsistencies between the attestation and a state or local public health agency's capabilities, notes attorney Brian Flood, with Husch Blackwell in Austin, Texas
- Providers that attest in 2014 using CMS' new "flexibility" rule. "It's a gut feel only," Koschka warns. "It's a potential red flag. It will be an area of suspect."