Best Practices For Preparing For A Meaningful Use AuditMay 24, 2013
ONC/CMS provides strong oversight of the meaningful use program by continuousy reexamining the quality of certified products and auditing hospitals and practices that have attested to meaningful use.
Last week, the ONC “de-certified” a product for not supporting the functionality required by regulations.
Meaningful use audits are done by Figliozzi and Company on behalf of CMS. Environmental Intelligence, LLC has experience with helping several of our clients effectively prepare and manage the meaningful audit process
What do the auditors ask for?
- Proof of ownership of a certified EHR
- Reporting method used to incorporate Emergency Department (ED) patients (All ED Visits or Observation Services)
- Core and Menu Measure Meaningful Use Reports used to enter attestation data
- Documentation for “Yes” attestation measures to evidence the measure has been met
Based on the information received, Figliozzi and Company will prepare additional follow up requests as needed. It’s helpful to retain all supporting documentation used while preparing for attestation so that it can be readily available for auditor followup requests. We strongly recommend that our clients place all supporting attestation materials in a shared folder which is accessible to the internal IT and Compliance staff.
The type of documentation we recommend to be stored includes:
- The organizations Certification process and approvals
- The organizations actual attestation documents and receipts
- Reports from the EHR which reconcile exactly to the attestations made for each Core and Quality measure.
- Documentation for Public Health measures with confirmation emails from contacts at the Public Health Agencies
- A statement about change control and source code control systems which documents that functionality such as Drug/Allergy Interaction Checking, Drug Formularies and Clinical Decision Support Rules was enabled for the entire reporting period
- Documentation that explains the interpretations made by management for all measures.
- Documentation regarding the validation performed for quality and meaningful use measure reports
Most EHR vendors have experienced the auditing process and can provide letters/supporting documentation that Figliozzi and Company will find suitable as proof that proper procedures were followed.
The bottom line is there’s a process for everything and no matter how daunting/irritating an audit seems, any organization can get through it if you maintain your equanimity and objectively respond to each request.
If you have not prepared or retained your Meaningful Use documentation, I recommend you prepare those binders and shared folders now.
You’ll be thankful when the auditors arrive.