By Marla Durben Hirsch
What should a provider do if it receives an audit letter from Garden City, New York-based Figliozzi and Company, the designated contractor for the Medicare audits, or from a state Medicaid auditor?
First, don't panic. "Others are going through this and help is available," says David Zavala, senior manager with consulting firm Protiviti in Dallas.
Then take these six steps:
- Engage the Meaningful Use audit team to respond: Respond with the requested documentation within the stated deadline, says attorney Brian Flood (pictured), with Husch Blackwell in Austin, Texas.
- Contact your EHR vendor: The vendor may have a toolkit or other resources that can help a provider survive a Meaningful Use audit. "They know their system the most, know its capabilities to complete reports, etc.," Zavala tells FierceEMR.
- Provide the auditors with a summary and table of contents of the security risk analysis, not the actual analysis, recommends Ed Koschka, IT Program Manager, Meaningful Use and Accountable Care Organization Programs for Franciscan Alliance, a health system based in Mishawaka, Indiana. You don't want to alert the auditors of weaknesses that you uncovered within your organization, especially since presumably, you've resolved any vulnerabilities that have been identified.
- Review all material before submitting it to an auditor: Make sure that it's accurate and complete. "It can affect how the audit goes," Flood says.
- Conduct a formal review of the audit, Koschka says. See what needs to be improved. "Meaningful Use is a long-term program, a 'forever' program," he points out.
- Consider appealing a negative determination if there's a good chance you can overturn it: Providers that fail a Meaningful Use audit should appeal if they have something to stand on, such as evidence that they met the Meaningful Use requirements or that the auditor committed a mistake. But if you can't go back in time and create evidence, such as screen shots. "You need to know the cause of your fail. It might be best to learn from your mistakes and move on," Zavala says.