To most people, the idea of a Meaningful Use audit brings about a good deal of fear and anxiety. But to those who have properly prepared and are educated on the matter, Meaningful Use audits do not seem nearly as threatening. A number of simple things can be done to ensure your Meaningful Use attestation holds up to an audit.
Before You Attest:
- Complete a Meaningful Use Audit Worksheet – Record your response for each objective and include supporting documentation. You should feel confident with each answer you provide. Spending the time detailing your responses will help you identify any holes that may be uncovered in an audit.
- Provide Detailed Supporting Documentation – Audits typically require supporting documentation for the objectives that you attest to. It is wise to acquire detailed supporting documentation during the actual reporting period. This includes screenshots and/or supporting written statements. Use enough detail in your supporting documentation that will not leave any doubt in the auditor’s mind as to whether or not you have satisfied each objective.
- Document and Perform Security Risk Analysis – Your HIPAA Security Risk Analysis documentation should be in place before your attestation and you should record the execution of your security risk analysis during your reporting period. Simple Security Risk Analysis templates can be found online.
- Create Copies – At the time of your attestation, save electronic copies of your MU Measures and CQM reports. If you get audited, you will be able to easily reproduce your reports.
During the Audit Response:
- If You Get Audited, Just Breathe! You’re Not Alone. – The CMS performs routine audits and you haven’t necessarily done anything wrong to trigger the audit. In fact, for the 2012 reporting period, approximately 1 in 4 physicians were audited by the CMS for Meaningful Use and the number of audits seems to be increasing for the 2013 reporting period.
- Be Detailed – Many times, physicians do not pass their audit on first pass because of a lack of detail on their audit response. Hopefully, tip #2 was already taken into consideration and you already have detailed supporting documentation that you can provide for your audit response. If not, spend the time gathering the appropriate screenshots and written statements to support your attestation. Remember to address everything required on the audit form, including each objective listed in the audit.
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