Hix said Carilion installed the filter on incoming e-mails after an audit notification letter was sent to a physician in a medical practice owned by the healthcare organization, not the official the eight-hospital system had designated as the person in charge of audits. The notice didn't make it back to the hospital officials responsible for complying with the audit demand until one day was left in the three-week response period auditors afford their targets.
“The CMS, they make their own rules about who they're going to contact,” Hix said. The filter is designed to flag future audit-related e-mails, Hix said. A designated employee monitors the system daily to look for those flagged audit notifications, she said.
Federal audits, which began in fall 2012, are expected to impact 5% of the more than 4,000 hospitals that have received federal incentive payments since the cash started flowing in 2011.
Thus far, the ARRA programs have paid $9.7 billion to hospitals for meeting their meaningful-use targets under Medicare and somewhat lower, initial qualifying criteria under Medicaid.
“A lot of whiplash” was how Pamela McNutt, senior vice president and CIO at Methodist Health System, Dallas, described their initial experience with federal audit contractor Figliozzi and Co., which added two more requests for additional records onto its initial demand for information.
“When we got our summons, our notice, we thought we were going to be well-prepared,” but the contractor—itself new to the audit program and was getting a lot of input and initial guidance from the CMS—changed its requests. “One minute we had to provide this information and the next minute we didn't,” McNutt said.
Methodist, which received payments under the Medicare and Medicaid portions of the ARRA programs, also was audited by the state of Texas, which required the hospital to prove its patient mix had a sufficiently large Medicaid component to quality.
“Finally, nine months after we started this process, we received notice that they had confirmed we'd met our charity care (requirement),” McNutt said. Methodist passed its Medicare and Medicaid incentive payment program audits, she said, but they weren't finished.
The office of inspector general at HHS also sent Methodist notice that it was going to audit the Medicare incentive payment audit program, and her hospital would be one of the test cases.
Detailed record-keeping is essential to surviving an EHR incentive payment audit, McNutt said. That's doubly important to providers who will be upgrading their systems for Stage 2 meaningful use and the Oct. 1, 2014, conversion to the International Classification of Diseases 10th revision of diagnostic and procedural codes. Auditors will be looking for documented evidence that providers have been using tested and certified technology eligible for use under the program.
“You need to prove that you were on a certified release the entire time,” McNutt said. “Every time you're doing an upgrade, if you're on the path of meaningful-use reporting, you need to think about that.
“You need to make sure you're on a certified platform the entire time of your attestation period,” she said. “You need to prove with screen shots the date your certified EHR technology went into production.”
Follow Joseph Conn on Twitter: @MHJConn
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