December 26, 2012
Just a few weeks ago, a practice called me because they had received a CMS Audit Letter from Figliozzi and Company, CPA, P.C. (contracted to audit on behalf of CMS) in order to prove their attestation for Meaningful Use and they shared that letter with me. I wanted to point out and share with you what is being asked for proof of attestation so that you can (hopefully) be prepared.
First of all, the letter indicated that according to the HITECH Act the Secretary has the right to audit and inspect any books and records for any Eligible Professional receiving an incentive payment. So if you are attesting or have attested to Meaningful Use for an incentive payment then you could be audited at any time. This initial audit was requesting the following information and did state that they have the right to request more information if needed:
- Proof of using a certified EMR for attestation. (This would be the certification number provided from your EMR company.)
- Listing of office locations using EMR for attestation. (Your offices where the EMR is being used.)
- Documentation such as screenshots for supportive information of all attestation measures, Core, Menu and Clinical.
Note – I must take a minute to remind you that they are asking for each measure to be supported with documentation (such as screenshots). If you attested or are thinking of attesting, be aware that you must provide supportive documentation for Core Measure #15 which states you performed a Security Risk Assessment and are attempting to mitigate the risk that the assessment uncovered. If you have not performed a Security Risk Assessment, you can order our security risk assessment here. And, if you have performed your Security Risk Assessment but have not begun to document compliance policies in accordance with the Risk Assessment, then you can purchase our suite of 34 HIPAA-Compliant Security Policies here.
If you need support with the policies, we invite you to join us in January for a workshop where we will help you customize the policies for your practice.
It is highly recommended that you take screenshots of your EMR system as you gather your numerators and denominators for attestation so that you have the required documentation handy for any audit requests. As always, if you need support, our Team at Practice Manager Solutions is here to help you.
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