A huge number of medical practices across the country are successfully qualifying for the government’s EHR incentive program, known as ‘Meaningful Use’. But quite a few are learning that there is still one big hurdle to overcome before they can fully reap the benefits of their efforts.

“Any provider that participates in the incentive program and receives money could be subjected to an audit,” said Amy Thorpe, the managing consultant at healthcare IT consultancy Encore Health Resources. She made these remarks during her presentation “Don’t Panic! Surviving a Meaningful Use Audit,”  at this year’s Healthcare Information and Management Systems Society (HIMSS) Conference in Orlando, FL.

Thorpe added that a Meaningful Use audit may be nerve-wracking because if you fail it, you will have to pay all the incentive payments back. However, she added that preparing for a potential MU audit should not be too difficult to achieve, “there are ways that you can minimize the impact of an audit and its pretty basic stuff,” she added.

Some of the suggestions by Thorpe to prepare for Meaningful Use audits include:

1. Have a clearly defined procedure in place to manage the entire audit process from start to finish. You need to identify who in your organization will receive notice of an audit, and make sure that they recognize it properly.
2. Ensure that you can produce the required documentation quickly. Once you get an audit notice, you will have two weeks to get together the information requested by the auditor. Additionally, you will be required to email the required information in a PDF format or upload it to the auditor’s portal.
3. You must also ensure that you assemble information that could be requested during an audit. Remember, you can be audited for up to six years post attestation. “This is not a particularly difficult prospect for the first year [of program participation] perhaps, but as we look at over five or six years as things are upgraded and new versions come out, to be able to maintain that install log, that audit trail, really is important,” Thorpe said.
4. Conduct a self-assessment which will tell you whether or not your practice is truly prepared for an audit. According to Thorpe, some of the questions you can ask yourself include:
   1. Are you keeping all of the source documents that you used during attestation?
   2. Have you thought about how you are going to store that evidence for six years?
   3. Do you have a robust system that would enable someone to find these documents five years from now?
   4. Can these documents be retrieved easily?
   5. Has your organization developed a clear vision for how it will respond to a CMS audit?
   6. Have you identified all of the people that would need to participate?
   7. Do they understand their roles and responsibilities?
   8. Have you held a mock audit, and was staff able to produce the information in a timely manner?

“If you pay attention to these kinds of things and do a little planning up front … you will probably be very successful,” concluded Thorpe.