This article is the second in a Two-Part series and includes helpful and timely tips to help you prepare for a Meaningful Use (MU) Audit.
Our previous blog post was a list of helpful tips to help you prevent an MU Audit. And perhaps you followed those steps and tips diligently, but you’re one of the unlucky ones.
According to a report issued by the United States Government Accountability Office, “CMS anticipates sampling roughly 20 percent of professionals, identified through random sampling as well as some targeted selections.”
If you receive an Audit Notification, here’s what to expect:
1 – Audits can be random or triggered. If information was entered incorrectly into the attestation website (such as a numerator that’s larger than a denominator), it’s possible that an Audit may be triggered. This is why it’s critical to take the time to properly attest. Additionally, if a provider participates in the program and then stops, due to retirement or lack of meeting a year of MU, it is likely Figliozzi and Company will audit the provider to see what has happened. However, many Audits are completely luck of the draw and random.
2 – There are different types of Meaningful Use Audits. Audits can be Pre-Payment or Post-Payment. Pre-payment Audits occur following attestation for a reporting period before CMS issues a check to the organization’s Tax ID number. Post-Payment Audits can occur following a payment that has been issued up to six years post-attestation. That means that organizations can be audited for a 2011 reporting period through 2017. This is why it’s critical to have great files!
3 – Figliozzi CPA Firm will email the email address on file. Ensure that whatever email address you enter with the attestation account is aware of Figliozzi and Company CPA Firm. Included in the email from Figliozzi will be a letter addressing the Audit, including for which provider and what reporting period year. Additionally, there will be documentation regarding what the Auditor is requesting to verify Meaningful Use was properly met.
4 – The practice will have a set time period to respond. Figliozzi typically gives two weeks from the time of your receipt of the Audit Notification until when your response is due. In some instances, Figliozzi allows for a longer time period to respond, so check your Audit Letter for the due date.
5 – You can request an extension. Many times, Figliozzi allows an extension for responding to the Audit, especially if the initial request is to respond in two weeks. We’ve found it’s better to provide a reason to why you are requesting the extension, but in our experience, initial requests for extensions are almost always granted.
6 – There are multiple ways to send files. Figliozzi will provide a secure file upload site, as well as the Auditor’s email address. Of course, no Patient Health Information (PHI) should be in either file. We suggest uploading via the portal and emailing the Auditor, requesting the Auditor provide confirmation that the information was received.
7 – The Auditors will clarify and request additional information. Typically Meaningful Use Audits are not one response requested and done. If the Auditor does not believe sufficient information is submitted to illustrate successful attestation for MU, the Auditor will email back a secondary request. In our experience, up to three submissions from the practice are available before the Auditor makes a final decision. Even so, the practice should do its best to answer and illustrate meeting all of the requested information upfront, the first time.
8 – At the end of the Audit, you will receive an Audit Notification Letter. Following the conclusion of the Audit, the Auditor will send a Final Notification that announces if the provider passed or failed the Audit. If the provider fails the Audit, CMS will request repayment of the incentive funds (or the funds will not be distributed if a Pre-payment Audit). Additional penalties could also ensue. There is the possibility of appealing an Audit, so it’s recommended you engage an experienced professional at that point.
Overwhelmed? Responding to Meaningful Use Audits appropriately is extremely important. One misstep could mean that your organization is immediately on the hook to pay back incentive funds received and the Provider will have a penalty against their Medicare Part B reimbursement. It doesn’t end there though! A failed Audit will mean additional reporting year Audits for that provider, and perhaps additional Audits for other providers within the organization.
In essence, responding to a MU Audit can incite a domino effect of one provider failing and then additional providers being targeted to see if they will fail as well. If you’re not completely confident in responding to an Audit, utilize a trusted partner, like your EHR vendor or a Business Associate Consultant who has experience responding to these types of Audits. Prevent the domino effect and protect the practice’s hard work to collect and retain the incentive funds.