Become Audit Proof. What You Need To Know To Protect Your Practice

Transcription

1 Become Audit Proof What You Need To Know To Protect Your Practice

2 Disclaimer This webinar is based on official guidance by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC), experiences from NJ-HITEC, and other Regional Extension Centers. It is by no means all-inclusive of the types of documentation you can keep to support your attestation, but this webinar provides a starting point.

3 Agenda Overview of the Audit Process Documentation Requirements 50% and 80% rule Meaningful Use Reports Screenshots Privacy and Security Requirement What can raise a flag? Best Practices Resources

4 The Audit Process

5 Audit Process Pre-payment checks are built into the Medicare and Medicaid Incentive Programs to detect inaccuracies in eligibility, reporting, and payment Post-payment audits will be completed during the course of the Medicare and Medicaid Incentive Programs If an auditor finds the provider not eligible for an incentive payment, the payment will be recouped CMS has an appeals process for eligible providers and hospitals that participate in the Medicare Program Each state will implement an appeals process for the Medicaid Program

6 Medicare Figliozzi & Company Performs all audits for the Medicare EHR Incentive Program Has a 3-year contract with CMS Started in July 2012 If you are selected for an audit, you will receive a letter from Figliozzi & Company with a CMS logo Questions can be directed to Peter Figliozzi: Phone: (516) ext at pfigliozzi@figliozzi.com Website:

7 Initial Information Request The following information will be included in the initial request from the auditor Proof of possession (Invoice, License agreement) Version Number Documentation for 50% rule (If the provider works at multiple practices) Documentation for 80% rule (If providers maintain records outside the EHR) CEHRT reports Documentation to support the Yes/ No measures (within a stipulated time period)

8 Follow-Up After the initial review process, you may receive a follow-up letter Auditors may require for additional documentation Clarification of provided documentation

9 50% Rule We proposed that to be a meaningful EHR user an EP must have 50 percent or more of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with Certified EHR technology -Page 44329, Stage 1 Final rule Providers may be requested to prove this, especially if they are practicing in multiple practices Reports from Practice Management System, Billing from all practices can be used to prove this

10 80% Rule The Denominator for Medication List, Allergy List and Problem List All Unique Patients Requires more than 80% of the provider s patients to be in the Certified EHR Providers can prove this by providing documentation from Practice Management System, Patient Roster, Billing system, etc

11 Meaningful Use Reports Important Points About Meaningful Use Reports Save a hard copy of the MU report Reports may not show the same numbers after a year Auditors request for dashboards with the vendor s logo, Provider s name, reporting period Save a hard copy your CQM reports

12 Meaningful Use Reports Double check the denominators for measures with the same definition Take screenshots of the steps to run the report Should be able to provide back up information for 80% rule

13 Screenshots Important Things to Remember When Taking Screenshots Screenshots / documentation should be created for all Yes / No requirements Clinical Decision Support Drug-Drug Drug-Allergy Interaction Health information exchange (Not needed in 2013) Drug Formulary Patient List Immunization registry Syndromic Surveillance Make sure your screenshots have dates from the reporting period

14 Screenshots Make sure the provider s name is on the screenshot CMS is requesting for one or more screenshots that will prove that the functionality was activated throughout the reporting period

15 Privacy and Security The providers will have to provide a risk assessment Auditors look for the risks identified Providers should have taken action on the identified risks in the risk assessment Providers should also save all the policies and procedures related to Core 15

16 What Can Raise a Flag to Auditors

17 What Auditors Are Looking For Different numbers on the report for the same denominator definition Problem list, Medication list, Allergy list, Patient Education Odd looking denominators Office visit denominator lower than unique patients Reconciliation / Summary of Care denominator greater than office visits Denominators are too low

18 Best Practices

19 Best Practices Talk to the auditor, they know the RECs Auditors are open to suggestions and alternate documentations Work with the vendor to look at the audit trail or obtain letter of support

20 Do NOT send PHI Best Practices Customized reports - should retain all documentation that demonstrates how the data was accumulated and calculated Create documentation for EXCLUSIONS, especially with public health requirements

21 Resources EHR Incentive Program Supporting Documentation for Audits Sample Audit Letter Audit overview

22 Thank You! Contact Us! Newark-Lawrenceville-Camden-Galloway