MU Audit Victim Lives to Tell

A provider who went through a Meaningful Use audit explains how she got through it, relying on training received at a user group conference and the help of her state's Regional Extension Center.

Don't be surprised if every third word I write for the next year or so is about Meaningful Use. It's a mountain we all must climb, but we're now well up on the slopes and have already encountered some challenges of late. No wonder that the calls for delay keep piling up.

But I have a snippet of good news on the Meaningful Use front this week. According to industry consultant Frank Poggio, the tally of EHR software certified for the 2014 Edition of Meaningful Use, including Stage 2, now stands at Epic, McKesson (Paragon only), Allscripts, Meditech. HMS, and CPSI.

According to Poggio, that still leaves Cerner, GE, Siemens, Healthland, QuadraMed, NTT-Data (Keane) and a host of others not yet certified. But hey, it's a start.

And more good news: for the first time, I've found a provider who went through a Meaningful Use audit, and survived.

South Arkansas Eye Clinic, founded in 2000, is the largest eye clinic in Union County, Arkansas, based in the county seat of El Dorado. Eighteen months ago, it implemented Allscripts PM practice management software and Medflow, eye-care-specific EHR software certified for Meaningful Use.

Shortly thereafter, Jeannie Atkinson joined the clinic as practice manager, which is how she came to be the lucky recipient of a CMS notice: the clinic had been selected for a pre-payment Meaningful Use audit.

"Lucky you," I congratulated Atkinson.

"I know," she replied with a laugh.

At least Atkinson was prepared. At a Medflow user group conference, she took a class on how to survive a Meaningful Use audit. "I was glad that I did, because it started me thinking about, okay, so what if I did get audited?" she said. "Would I be ready for it?"

Atkinson had another valuable resource to turn to: HITArkansas, the state's Regional Extension Center.

"They had created a binder for us, that walked us through the core measures we needed to attest to, what measurements we needed to meet, what documents we needed to keep, what security risks [existed], the way we documented.

Receiving the notice of audit triggered a brief feeling of panic, but then Atkinson called Valerie Moring, implementation specialist at HITArkansas.

"When Jeannie had originally called me, I sent an email out to all of the other specialists that we worked together with, to see if anyone else had received requests like this yet," Moring says.

They had not. It was also one of the first pre-payment Meaningful Use audits. "Initially when Meaningful Use came on, a lot of the providers who jumped on board really fast, they attested, and CMS just basically just paid them right and left," Atkinson said.

In fact, approximately 5 to 10% of providers will be selected for pre-payment audits. Selections will be made both randomly and also based on protocols that identify suspicious or anomalous attestation data. Post-payment audits will also affect approximately 5-10% of providers who submit attestations through the program. The scope of both the pre- and post-payment audits is consistent with the scope of audit strategies for similar CMS programs.

CMS said "wait, hang on just a minute. We shouldn't be auditing after the fact. Maybe we should stop, slow down and before we give the money out, and we have to take it back, let's start doing pre-payment audits. And that's what they've started doing this year."

CMS speeds up the audit process by providing a portal, operated by the accounting firm Figliozzi & Company, allowing providers such as South Arkansas Eye Clinic to scan and upload required documents, rather than trusting them to the U.S. Postal Service.

With recent talk about the forthcoming ending of funding for HHS' national network of Regional Extension Centers, it's worth noting that HITArkansas is part of a larger concern, the Arkansas Foundation for Medical Care, a 40-year-old state quality improvement organization.

According to HITArkansas director Nathan Ray, his REC has helped more than 1,400 primary care providers and specialists around the state. "We've got over 52 percent of our target to Meaningful Use," he says. "We're out there helping clinics such as Jeannie's with actually making sure that they are compliant with the Meaningful Use criteria, helping them where there are gaps."

I was curious about what is in HITArkansas's helpful binder. According to Ray, it covers assessment and planning; selecting an EHR vendor; implementation tools, checklists and strategy guides; a post-go-live EHR evaluation guide; Meaningful Use criteria; security risk analysis; and details of registration and attestation.

Ray says different institutions have different ways of saving paperwork in case of audit. Some use Microsoft Sharepoint or similar document management technology. Others upload it to a secure area of their network.

"We had actually backed ours up on a shared hard drive," Atkinson said. "It was a really easy, simple process just to go there and like Valerie says, just zip all that up that they were requesting and asking for, and submitting it to them."

The clinic received two responses from CMS. The first request, received in March, requested supporting documentation on all of the Meaningful Use quality measures. Then, at the end of May, CMS requested more documentation on Core Measure 5, the Active Medication List.

Atkinson once again called Moring, who helped her gather the final round of documentation and draft a cover letter. Finally, in July, the final letter from CMS arrived: South Arkansas Eye Clinic had passed the audit.

It must have been a great feeling.

"It was," Atkinson said with a laugh. And it didn't hurt that the Meaningful Use Stage 1 incentive check arrived shortly thereafter.

One other note for specialists reading this: Atkinson checked with the American Association for Ophthalmology Practices and the regional Arkansas Eye Association to determine and confirm which exclusions to Meaningful Use quality measures applied to them. "A good example would be, when you go into a doctor's office, they're going to take your basic vitals and record your height and weight and your blood pressure," Atkinson said. "We don't do that. It's not in our scope of practice, and so we took that as an exclusion." Other specialists are well-advised to check with their own professional associations for similar information.

Want more good news? Atkinson says future CMS Meaningful Use guidelines will change some criteria to be more specific for specialists, meaning faster attestation and simpler audits. Hooray for that.