As of June 2012, the Centers for Medicare and Medicaid reports more than 100,000 healthcare providers received payments as part of the Medicare and Medicaid Electronic Health Record Incentive Programs.

Now, CMS has begun its first wave of required retrospective audits for those providers paid under the “meaningful use” EHR incentive program; CMS contracted with the firm of Figliozzi and Company to conduct the audits. The auditors will request information from providers via a letter of inquiry asking for specific, non-identifiable patient information from the EHR system.

Garden City, N.Y.-based accounting firm Figliozzi and Company, acting on behalf of CMS, has started to send letters to providers requesting them to send documentation to support their attestation for meeting the meaningful use requirements. According to the law firm Ober Kaler,  the auditor is asking for four types of information:

• A copy of the provider’s certification from the Office of the National Coordinator for the technology used to meet the program’s requirements, to show that the provider has a certified EHR system;
• The method used to report emergency department admissions, which affects some of the required measures;
• Supporting documentation for the completion of the attestation about the core set objectives and measures; and
• Supporting documentation for the completion of the attestation about the menu set objectives and measures.

Eligible providers and hospitals must remember the following when responding to the audit:

• Look for a CMS logo on the letterhead of the audit letter.
• Know the Eligible Professional audits will be for Medicare and Medicare Advantage programs; Eligible Hospital audits will be for Medicare Only and Dual Eligible, including Medicare Advantage Hospitals.
• CMS advises avoiding detailed audit responses, and site visits are not being conducted.
• Protect patient confidentiality and de-identify patient information, per HIPAA requirements.
• Provide only the information requested by the audit letter; “less is best.”
• Respond to the audit in a timely manner – within two weeks from request.
• Ask questions about the audit, if not sure how to respond.
  • Meaningful use audit questions can be directed to Peter Figliozzi at (516) 745-6400 x302 or by email at pfigliozzi@figliozzi.com. Figliozzi and Company’s website is http://www.figliozzi.com/.

I would be interested in hearing from Eligible Professionals and Eligible Hospitals on their audit experiences. Please share any of your insights and comments here on the HIMSS Blog.