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Auditing Community of Practice (CoP)
Medicaid Electronic Health Record
(EHR) Incentive Program
September 24, 2015
This is an advanced copy of the Auditing
presentation for your review only. This presentation
is subject to change and should not be reproduced.
The final version of the presentation will be posted
to the Medicaid HITECH TA Web site at a later date.
Agenda
2
Florida Auditing Outreach
Audit Strategy Updates
Question and Answer Period
Upcoming Auditing CoPs
In Florida . . .
• Contracted with KPMG, LLC.
• Audits began in 2012
• Audit pool includes payments made during
the previous state fiscal year – July
through June
• Prepayment Review
September 24, 2015 4
Audit Results through July 2015
September 24, 2015 5
Of the 28 audits with a finding:
16 have been remediated,
4 payments have been recouped
1 payment plan
7 attempting to remediate
Three Years Audit Coverage
September 24, 2015 6
Audit Process Timeline
Select Auditees from relevant Stages
Audit Notification and Information Request
Completion of Audits Notification from AHCA
of Audit Findings
• Audit selection occurs approximately seven months after the end of the
program year
September 24, 2015 7
Documentation Request • The documentation request list(s) will ask providers to produce
reports and screen shots that support information attested to.
Patient Volume
• Provide a patient-level detail report that supports the numerator and denominator attested to in your application.
Meaningful Use Measures
• Provide documentation that demonstrates each of the Core and Menu Measures attested to were met.
September 24, 2015 8
Why Outreach?
September 24, 2015 9
Outreach Efforts
September 24, 2015 10
Audit Results
Audit Focused Webinars
Tip Sheet
Workshops
FAQs
Other Webinars
Pre-Payment
Processing
July 23, 2015 11
http://www.ahca.myflorida.com/medicaid/ehr/dow
nloads/AuditTipSheet.pdf
July 23, 2015 12
Common Meaningful Use Audit Issues
• Conduct or review a security risk analysis (SRA) and implement
security updates as necessary, and correct identified security
deficiencies as part of the risk management process
– Maintain completed, signed, and dated documentation that an SRA
was performed during the program year prior to attestation
– Document identified deficiencies and mitigation plan
• Attesting to an exclusion correctly
– Understand when it is appropriate to claim exclusions to measures
– Supporting documentation (i.e. dashboard) should show an EP
qualified for an exclusion.
July 23, 2015 13
Common Meaningful Use Audit Issues
(continued)
• Providing sufficient documentation to support the specific requirements within
the objective of the measure were met (i.e. clinical summaries)
– Documentation should include the required fields specified in the objective for the
measure
– Preparing documentation at the time of attestation may help to avoid issues retrieving
data at a later date
• Providing sufficient documentation to support Core and Menu Measures
– EPs are encouraged to maintain support for all measures for at least two patients in
case of system changes, staff turnover, and inability to access information at a later
date
– Dashboard alone is not enough
July 23, 2015 14
July 23, 2015 15
September 24, 2015 16
Success
Small practices lack resources
Persons responding to audits are not necessarily the ones that participate in
webinars/meetings
Document everything
Prepare at time of attestation
Does Not Have to be Negative
Response to Audit Notification
Thank you so much for planning this audit at
the same time every practice in the United
States is rushing to prepare for ICD 10. You
sure want to increase the suicide rate of
physicians!
September 24, 2015 17
Public Health Documentation
• There have been some issues as to what the Medicare auditors accept as Public Health measure verification
• CMS will be issuing a survey to all the states and territories regarding the documentation issued by Public Health verifying EP/EH communication (contact; testing, on-going status)
• The states will be asked to provide sample copies of the states’ PH verification documentation
• CMS will work with the Medicare auditors to determine their requirements
18
CHPL Update
CHPL now has a CMS Certification ID look up!
19
Audit Strategy Updates
The Audit Strategies equate to Section D of the SMHP; the public copy of the SMHP should note include audit discussion
Any changes to your audit strategy – including pre- and post-payments changes – need to be submitted and approved by CMS prior to implementing the changes
Updated Audit Strategies should be submitted as the whole document with re-lined changes. Audit Strategies are not updated with addendums
20
Audit Strategy Evaluation Criteria
Each Audit Strategy is evaluated on the following criteria:
21
Audits done by State Medicaid Agency (SMA) or Contractor Audit Document Sources
Who conducts Eligible Hospital (EH) Meaningful Use (MU) audits? Field Audit Triggers
Pre-payment Patient Volume (PV) Verification* How report audits to CMS
Pre-payment Certified EHR Technology (CEHRT) Verification* Who conducts appeals?
Pre-payment MU Verification* Does the SMA have an All-Payer Claims Database (APCD)?
Number of Staff Reviewing Pre-payment* Automated interfaces to Public Health Association (PHA)
Provider Letter Template* How you receive documentation from providers
Audit Checklist* How do you store audit documentation?
How many risk categories? Recoupment process
Audit selection % by risk category Risk factors or categories for MU
Audit All or Questionable
Audit Strategy Criteria
Audits done by State Medicaid Agency (SMA)
or Contractor – for both pre- and post-payment
Who conducts Eligible Hospital (EH)
Meaningful Use (MU) audits? – CMS vs. the
agency; for dual eligible and/or Medicaid only.
Appropriate designation language is required (next slide)
22
Audit Strategy Criteria
The state electing the option for Medicare to conduct MU post-payment audits for dual
eligible (and Medicaid-only) EHs are required to:
(1) designate CMS to conduct all audits and appeals of EHs meaningful use
attestation;
(2) be bound by the audit and appeal findings;
(3) perform any necessary recoupments arising from the audits; and
(4) (4) be liable for any FFP granted to the state to pay EHs that, upon audit (an any
subsequent appeal) are determined not to have been meaningful EHR users.
Any adverse CMS audits (for states that have made the election) would be subject to the
CMS administrative appeals process and not the state appeals process.
The state should include a signed agreement that the state has opted for CMS to conduct
such audits and appeals and agreeing to the 4 provisions noted in the first paragraph of
this section.
23
Audit Strategy Criteria
Pre-payment Patient Volume (PV) Verification – process (Medicaid Management Information System [MMIS]; Decision Support System [DSS])
Pre-payment Certified EHR Technology (CEHRT) Verification – use of CHPL; how access (web services vs. manual lookup)
Pre-payment MU Verification – what level; quick review; review of similar denominators, etc.
24
Audit Strategy Criteria
Number of Staff Reviewing Pre-payment – how many different staff review attestation before final determination
Provider Letter Template – copy of letter(s) sent to providers
Audit Checklist – minimally for post-payment audits; can include pre-payment
How many risk categories?- developed from risk assessment (e.g. 3, 4, 5)
25
Audit Strategy Criteria
Audit selection % by risk category – the details of your audit selection process; how determine
Audit All or Questionable – look at everything on a post-payment audit; or only those elements that seem incorrect
Audit Document Sources – what sources do you use – and where to they come from? Provider supplied; MMIS/DSS; APCD
26
Audit Strategy Criteria
Field Audit Triggers – adverse desk audit?
EP lack of cooperation with desk audit? All
High Risk EPs?
How report audits to CMS – manually
enter into R&S UI or electronically via an E7
Who conducts appeals? – the HIT team only? Overall agency appeal process?
27
Audit Strategy Criteria
Does the SMA have an All-Payer Claims Database (APCD) – you may want to indicate if you do not have an APCD
Automated interfaces to Public Health Association (PHA) – how do you verify the Public Health measures?
How you receive documentation from providers – indicate what secure methods you use for audit documentation you request; upload to SLR; secure email; encrypted DVD/flash drive; USPS
28
Audit Strategy Criteria
How do you store audit documentation?
– post payment audit documentation; paper
in a secure filing location? Agency network
drive? And for how long to you retain the
documentation?
Recoupment process – what is your
process? Do you request a check? Recoup
via MMIS? Set up and payment plan?
29
Audit Strategy Criteria
Risk factors or categories for MU – do
you conduct a risk assessment on MU
measures? Are the findings part of your Risk
categories?
2014 Flexibility Rule – have you added
your process for auditing attestations
submitted via the Flexibility Rule?
30
Questions and responses from this webinar will
be provided for your reference after the call.
Please enter your question in the “Questions”
pane in your control panel.
Thank You!
31
Upcoming CoPs
32
Auditing CoPs will be held every other
month in 2015; still the 4th Thursday at 2 ET;
except for November – which is the next
Auditing CoP!
The next Auditing CoP is scheduled for
November 19 (3rd Thursday) – Watch for
appointment!