Preparing for a meaningful use audit

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, 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. I've assisted one of our hospitals and one of our practices with such audits.

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've placed all our materials in a shared folder which is accessible to IT and Compliance staff.

The type of documentation we've stored includes:

  • Our Certification process and approvals (we self-certified our systems)
  • Our actual attestation documents and receipts
  • Reports from our 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 we did 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.

I tell my staff that there is a process for everything and no matter how daunting/irritating an audit seems, you'll 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.