If your practice received Medicare or Medicaid EHR grants, then it may be subject to an audit from a Centers for Medicare & Medicaid Services (CMS) contractor.
These audits ensure that your practice is fully compliant with meaningful use standards.
CMS uses contractors to conduct audits of recipient clinics participating in the Medicare EHR incentive program, the state Medicaid program or both programs. Different state Medicaid programs use different contractors to conduct the audits, so your auditor may vary depending on where your practice is located. Being prepared in advance with information about your eligibility, including documentation, helps your clinic when the auditor arrives.¹
Eligibility and documentation
During the audit, the auditor will review your clinic’s use of EHR. Using your own documentation, you can demonstrate compliance. Have this documentation available to submit to the auditor—they may ask for additional documentation or may need to verify it. If your documentation was not generated as part of a report created by your EHR, then you will likely be required to show how you obtained the data and documentation.¹
The main evidence the auditor looks for is verification of the clinical quality measures you reported and the original document you used when you filed your attestation. You are expected to submit the information on clinical quality directly through a certified EHR system, so the data you retain should be the same as what you submitted, or you should keep records that explain any discrepancies.¹
Meaningful use objectives
For the specific measures that apply to your clinic, you should verify with CMS or with your state Medicaid program, depending on the incentive you participate in. Meaningful Use specifies a certain level of functionality for your system, including:¹
- Clinical Decision Support: Your EHR should have clinical decision support functionality enabled. You can document this with a screenshot.
- Clinical quality reporting: The system should be able to report clinical quality data directly. This information should reflect what you reported when you completed your attestation.
- Electronic transfer of information: Your EHR should be able to successfully transmit information to another EHR with a different provider. To document this, you should complete a test information transfer and keep dated records showing that the other clinic successfully received the test data. This could be a piece of evidence such as a screenshot, letter or email from the other provider, showing the test succeeded.
- Patient information security: EHR should protect patient information and you should conduct a risk analysis to ensure that your system properly secures patient data.
- Drug checks: Although chiropractors do not typically prescribe drugs, they are required to use a complete EHR system that includes a verification program checking for prescription drug interactions and allergies. Now, some of the drug-related standards may be waived for providers writing fewer than 100 prescriptions per year or not prescribing drugs. In some cases, drug functionality may be excluded from your system as long as the vendor makes it available to your clinic upon request.²
- Create lists of patients by condition: Your system should be capable of generating lists of patients by condition. When you attest, your system will generate a list—keep a copy. You can blur sensitive patient information first.
- Submit public health data: Your EHR should be capable of submitting data to public health agencies and immunization registries. Keeping a record of successful test transmission may help you fulfill this requirement.
Audit-ready
Preparing these records and keeping them for each year you participate in the program may help you stay ready for an audit. Be sure to independently verify all requirements and check your records for accuracy, as government programs such as EHR incentives are always subject to change. Your own clinic’s needs may vary, so do what you can to obtain the best information.
References
¹CMS, “EHR Incentive Programs Supporting Documentation for Audits,” https://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/downloads/ehr_supportingdocumentation_audits.pdf. Published: February 2013. Accessed: July 2016.
²Brown, J. “EHR Incentive Program ‘Drug’ Requirement–Why Chiropractors?” ACOM Health Blog. http://www.acomhealth.com/ehr-incentive-program-drug-requirement-why-chiropractors/. Published: September 2011. Accessed: July 2016.