06/20/2013    Daniel D. Michaels, DPM

HITECH EHR Meaningful Use Audit

Dear Colleagues,

Our office would like to share the experience
that we encountered during an audit from
Medicare for HITECH EHR Meaningful Use. Bottom
line - use exact dates on the letter from your
EMR company proving you have met meaningful use.

On January 11, 2013, we submitted our Attestation
report for 2012. It was our understanding that
once the submitted information was complete there
would be a 30-60 day window for the stimulus
monies to be disbursed. At the end of March there
were still no monies received, therefore we
contacted CMS and they stated the funds were in
processing.

Finally, at the end of April, there were still no
funds received, so there was another call made to
CMS. Now they have stated that the funds have
been put on hold because there is possibly an
audit that is in progress.

On May 3, 2013, we received an email from
Figliozzi & Company stating that our practice had
been chosen for a HITECH EHR Meaningful Use
Audit. The information they were requesting was
as follows:

*Proof of using a Certified Electronic Health
Record Technology System which identifies the
vendor, product name and product version number
along with a letter from the vendor attesting to
the version number used during the attestation
period.

*Supporting documentation used to complete the
Attestation Module responses

*A report from the EHR system that tied to the
responses of the attestation.

There was a deadline of May 31, 2013 to get the
requested information faxed. We were able to get
all the information requested, including the
letter from our EHR vendor faxed before the
deadline. There was an email confirmation that
confirmed the information had been received and
if there was anything further that was requested
another email would be sent.

After contacting Figliozzi & Company once a week
to see what the status was on the audit, the
answer was “we have many other audits and we will
let you know when your audit is complete.”

On June 11, 2013, an email was received from
Figliozzi & Company that stated the documentation
that was provided from our EHR vendor did not
sufficiently demonstrate access of the entire
attestation period. In order to be eligible for
the stimulus payment another letter needed to be
received within 24 hours.

Please take note, the letter that was originally
received from our vendor stated the attestation
year, 2012, and not specific dates, 1/1/12 thru
12/31/12, which is what the auditing company was
looking for. Fortunately, the letter was received
by the auditing company by their deadline. I hope
this information is helpful to anyone who may be
audited in the future to make sure the exact
dates are used for the entire attestation period
and not just the year.

Daniel D. Michaels, DPM, Hagerstown, MD
drmichaels@rfainstitute.com

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