Issue link: https://viewer.e-digitaledition.com/i/336371
staff members are clearly defi ned prior to and during an audit to make data submission as seamless as possible. If a prov ider is audited, proof of software use and ownership as well as a report demonstrating that functionality was enabled during the reporting period may be requested. Medicaid audits by the state are typically more fi nancial in nature and may require the supporting documentation for calculating eligibil- ity as well as describing the services rendered to patients. A n OIG audit requires information similar to that requested in a state audit but may also ask for patient-level details to validate the state's decision to certify a provider as a meaningful user. Do not hesitate to ask for clarifi cation about what needs to be submitted as part of the audit, and be prepared to produce proof of a thorough risk assessment analysis as prescribed in EHR meaningful use regulations. ■ Reducing the By Melissa Moore AFTER MONTHS OF LABORIOUS DATA COLLECTION, COMPLETING THE ATTESTATION PROCESS OF PROVING MEANINGFUL USE FOR AN ELECTRONIC HEALTH RECORD (EHR) INCENTIVE PROGRAM IS A RELIEF. HOWEVER, ANY PROVIDER WHO RECEIVES INCENTIVE FUNDS MAY BE SUBJECT TO A MEANINGFUL USE AUDIT. SOME FORETHOUGHT AND PREPARATION CAN MINIMIZE THE STRESS OF AN AUDIT. o f M e a n i n g f u l U s e A u d i t s STRESS D EPENDING ON WHICH agency p r o v i d e d E H R i n c e n t i v e funds, a provider may experi- ence any one of these audits: + A Medicare audit instigated by the Centers for Medicare & Medicaid Ser vices (CMS) and completed by agencies with which CMS contracts + A Medicaid audit completed by the state and its agencies + A n aud it f rom t he O f f ice of t he I n s p e c t or G ener a l (OIG). I n a n OIG audit, the state itself is being audited, but providers are required to resubmit meaningful use data. Audit Readiness 101 A guiding principle for audit readi- ness is ensuring that data can be quickly and easily accessed and submitted up to six years down the road. "Prepare for an audit as if the people who prepared the attestation data are not available," says Amy Thorpe, MBA, PMP, FHIMSS, Managing Consultant at Encore Health Resources. "Would others be able to access attestation data — including proof of ownership for EHR vendors — in three years? This mind-set covers so many bases. Start with a dedicated email address for communication about meaningful use attestation." Additionally, ensure that data are stored electronically. "Once the audit notice is received, there's an expectation of submitting data t hrough a n online por ta l in a short amount of time," Thorpe says. "Having the data in a filing cabinet somewhere is going to make that quick turnaround diffi cult." Before being cont acted about a n audit, providers should have a procedure in place to respond to the notice. Make sure the roles and responsibilities of CORE ++++++++++++++++++++++++++++++ + +++ + +++ ++++++++++++++++++++++++++++++ PRACTICE MANAGEMENT 1 6 | Long Island MD NEWS ■ M D N E W S . CO M