We are now less than a month away from the CMS Final Rule that will affect Medicare Part B reimbursement far into the future. It is expected that the majority of these providers will fall into the MIPS (as opposed to the Alternate Payment Model) bucket and be subject to the zero sum competitive horse race in which those with high annual composite performance scores will receive incentives that come from what is taken away from the low scorers.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal."
Meaningful use audits against 2015 attestations are currently underway. Through our work at MeaningfulUseAudits.com we have found that there are specific areas of attestation documentation that are particularly difficult for Eligible Hospitals (EH) and Critical Care Hospitals (CAH).
In the past week I have been contacted by four Eligible Professionals (EP) who have been notified they were being audited by Medicare for their CMS EHR Incentives. In all cases the audits were based on 2011 meaningful use (MU) attestations.
The long awaited Final Rule gave providers a clearer view for 2015 – 2017 and Stage 3 Meaningful Use (MU). Some of the most fascinating details are found in the nuances buried in the response to public comments.
One of the more common questions we are asked at Meaningful Use Audits has to do with how long after attestation can a CMS Meaningful Use audit take place. What is the look back period? When it is OK to breathe easy?
Given what is at stake, preparing for a pre or post-payment audit of a CMS EHR incentive should be considered part of the entire meaningful use process. And while attestations can be withdrawn, they cannot be withdrawn during an audit.