We don’t know exactly what may be required or if actual audits with hospitals and providers will take place, but as a precautionary measure the American Medical Association offers some guidelines and answers as to what you may need should an audit of your incentive funds take place. 

The first suggestion is simply using a screenshot program showing the technology was in place and working during the reporting period.  There are various free programs that can do this for you or you can simply use the “print screen” function on a keyboard to capture and save the visual images.

In addition save your documents that demonstrated the risk assessment had been completed with the EHR system you are currently using.  The last recommendation is relative to showing the number of patients to meet the qualifying numbers.  Most have no problem in this area as when you do a system conversion and to imagework a paper records system along side a medical records program, it would be more work, but again the evidence should not be hard to gather as most systems have various reporting abilities and/or registry functions that could easily generate substantiation in that area.  There is the transition stage of going back and forth with paper and depending upon when you attested many at current time have more than likely far exceeded those original percentages.

As mentioned by the AMA extremely complicated audits would delay payments to doctors and hospitals and the AMA disagreed with the Office of the Inspector General requiring pre-audits but then again you have to remember the OIG will come forward with the most stringent requirements they can suggest which may not always be the complete solution but their job is auditing and perhaps a happy balance here will be reached on this topic.  The system as it stands today does a pretty good job and there have been a couple payments made in the incentive areas by mistake but they were not related to attesting, but rather bookkeeping errors and the money was returned.

Below is what the AMA News suggested via their website today.

Physicians and hospitals are expected to retain supporting documentation to back up their meaningful use attestation statements, according to officials from the Centers for Medicare & Medicaid Services. Physicians and hospitals, for instance, should hold onto the following records:

  • Computer screen shots showing required EHR technology functions were enabled during the reporting period.
  • Documents verifying a security risk assessment was conducted.
  • Evidence documenting the number of patients, including those with paper records, for percentage-based measures with all-patient denominators.

Source: “Early Assessment Finds That CMS Faces Obstacles in Overseeing the Medicare EHR Incentive Program,” Dept. of Health and Human Services Office of Inspector General, Nov. 28 (oig.hhs.gov/oei/reports/oei-05-11-00250.pdf)