Issue link: https://viewer.e-digitaledition.com/i/155901
inaccuracies in eligibility, reporting and payments. Audits will be random, as well as targeted when "suspicious or anomalous data" is detected. For both pre- and post-payment audits, it is vital to provide supporting documentation to validate submitted attestation data. This information must be retained for six years. According to CMS, the primary documentation that will be requested in all reviews is the source document(s) used when completing an attestation. The most compelling form of documentation from CMS's perspective is that which comes directly from certified EHR technology. It is acceptable, however, to use non-EHR-generated data in some cases. To be on the safe side when doing so, it would be a good idea to consult with CMS first. Most of the time, the starting point for EHR auditors is a report summarizing measure data that includes numerators and denominators, the time period of the report, and proof that it was generated for the specified eligible professional. Subsequent steps might involve a more detailed assessment of information that supports the measures, including a review of patient records. The practice should be able to support each measure it has attested to as well as any exclusion claimed. It is critical that on the day of attestation, the practice make copies of all reports utilized from the EHR and even screenshots when needed. (This may be necessary for clinical quality measure data for some EHRs.) It is also important that the submission receipt provided after a successful attestation on the CMS portal be printed and saved. For measures that do not involve a percentage, CMS may request additional supporting documentation. On the opposite page is a CMS table with information that pertains to these measures. Preparing for an EHR audit well in advance of one by maintaining an "audit book" with all the information mentioned above, as well as the reasons behind decisions the practice makes throughout the process, will stave off a great deal of worry and concern for practice administrators. EHR audits will likely become just another aspect of running a medical practice in today's environment. Taking commonsense steps should ensure all will go well if an audit actually occurs. John Netti is President of Netti Consulting Services, www.netticonsulting.com, which provides an array of EHR and meaningful use services, as well as President of the Mountain Creek HIPAA Group, www.mchipaagroup.com, which provides privacy, security, breach and risk management services. He can be contacted at jnetti@netticonsulting.com or 315-437-4377. ■ Bachelor Degree in Health Services Administration. The healthcare field offers a number of career tracks. For individuals interested in the administrative side of the healthcare industry, Bryant & Stratton College is pleased to offer a Bachelor degree in Health Services Administration. This program is ideal for those who may already be working in healthcare administration, or those working on the clinical side and are seeking new and different challenges. For more information about our graduation rates, the median debt of students who completed the program, and other important information, please visit our website at www.bryantstratton.edu/disclosures. w w w . b r y a n t s t r a t t o n . e d u Bryant & Stratton College Personal Education. Lifetime Success.® Since 1854 facebook.com/BSCSyracuse • facebook.com/BSCNorth Liverpool Syracuse 1.315.804.4004 Scan here with your smartphone for more information. MDNEwS.COM ■ MD News Central New York | 15