By Kendra Casey Plank
The Centers for Medicare & Medicaid Services has begun conducting audits
to determine compliance with “meaningful use” program reporting rules, a CMS
spokesman confirmed to BNA July 24.
The spokesman declined to provide additional details about the audit program,
but in a July client alert
, attorneys James B. Wieland and Joshua J. Freemire with Ober Kaler in
Baltimore, wrote that clients had begun receiving audit letters from CMS
contractor Figloiozzi & Co., in Garden City, N.Y.
Freemire told BNA all the audit letters to health care organizations appear
to be similar.
According to the Ober Kaler alert, the audit letters request four categories
of information from participants in the Medicare and Medicaid Electronic Health
Record Incentive programs:
of their certification from the Office of the National Coordinator for Health
Information Technology for the EHR technology they used to meet program
to support the method they chose to report emergency department admissions;
documentation used to complete the attestation module for core set objectives
and measures; and
documentation for the attestation module responses about meeting voluntary
objectives and measures.
Wieland and Freemire wrote that the audit letter recipients were given a
two-week time frame in which to respond to the requests.
“Unfortunately, it is also unclear how audit candidates are selected, so
hospitals and professionals will not be able to 'plan ahead' for an audit they
can be certain is coming,” they wrote.
Nevertheless, Wieland and Freemire wrote that while audit letters “are always
nerve wracking,” the requests thus far are not “the type of specific, targeted,
detailed investigation that can give rise to significant operational
interruptions and expense.”
It appears, they added, that the audits will be “very basic desk” audits and
likely will be used as a basis for future meaningful use audit
CMS has not formally announced the start of the meaningful use audits, but
has said they were imminent. In a frequently asked question post (FAQ
No. 7361) on its website, CMS identified Figliozzi & Co. as the contractor
hired to perform the audits.
“Figliozzi and Company will be performing the meaningful use audits for CMS.
If you are selected for an audit you will receive a letter from them with the
CMS logo on the letterhead,” according to the FAQ response.
Robert Anthony, insurance specialist in CMS's Office of eHealth Standards
& Service, said July 23 that CMS would not issue guidance on what meaningful
use program participants should expect from the audits, saying it would defeat
the oversight purpose of the audits (see previous article).
The Ober Kaler alert is available at http://www.ober.com/publications/1882-figloiozzi-company-begin-meaningful-use-audits-cms-designee.
CMS FAQ No. 7361 is available at https://questions.cms.gov/faq.php?id=5005&faqId=7361.
Additional information about planned meaningful use program audits is
available at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Attestation.html#10.