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Meaningful Use Audits

Figliozzi and Co

Figliozzi and Co. have been appointed as the acting auditors for Meaningful Use. Providers who recently received their meaningful use stage 1 incentives, were sent notices from the audit company to provide them with the attestation material. Although CMS has not confirmed the engagement Figliozzi and Co. officially, a CMS spokesman has confirmed that the audit program has indeed begun. In addition, CMS has enlisted the company as an audit contractor on its website in an answer to a question (FAQ No. 7361). Attorneys from Ober Kaler believe the letters to be legitimate, alerting the medical community about the audit commencement.

CMS utilizing its statutory authority under the American Recovery and Reinvestment Act (ARRA) will audit providers for the meaningful use of Electronic Medical Records as per the criteria outlined in the stage 1 objectives. Ober Kaler, the law firm outlined four categories of information that is required from the providers participating in the audit.

1.)A copy of their certification from the HHS Office of the National Coordinator for Health Information Technology for the EMR technology the entity used in meeting the meaningful use requirements.

(Ober Kaler believes this to be a documentation that can demonstrate that the participating entity does in fact possess a certified Electronic Medical Record system as required under Meaningful Use.)


2.)Documentation to support the method used by the participating entity for reporting emergency department admissions.

(Ober Kaler believes that this information would be used to determine which patients were included in the denominators of the Meaningful Use Core and Menu objectives.)

3.)Documentation supporting the completion of the Meaningful Use core objectives and measures.

4.)Documentation supporting the completion of the Meaningful Use menu or voluntary objectives and measures.


(Ober Kaler believes these to be requests for reports that can be used to substantiate completion of the Core and Menu measures along with the respective calculation for the attestation process.)

While the letter states that the information provided will be kept confidential, the law firm advices physicians to de-indentify data before submitting it for audit and that they should provide the absolute minimum necessary information requested.

However unlike most audits, the request for information seems nominal, coming as a relief for most providers anticipating much thorough investigation. Most of our clients were concerned that the audit proceeding could hamper operations and cause interruptions resulting in loss of revenue., says Tony Keller a Health IT and Meaningful Use consultant at CureMD, a leading EMR vendor. The broad testing criterion of the audit suggests that the information generated initially could be used to plan other subsequent audits. On the other hand, whats been a surprise for most is the time allotted to conjure a response. Keller adds, Two weeks is a very short span of time, particularly for smaller practices with limited staff.

by: Frank Quinn
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