The Office of Inspector General (OIG) has begun to audit providers’ compliance with the meaningful use electronic health record (EHR) incentive program. While similar to those that are being conducted by The Centers for Medicare & Medicaid Services (CMS) contractor, these audits do differ in several ways:
- The OIG is looking at multiple years at once, while the CMS contractor is looking at a single attestation year at a time. With the OIG looking at multiple years at a time, this puts more money made by the provider who fails the audit at risk.
- The OIG allows providers 30 days to respond to document requests, while the CMS contractor deadline for documents is much shorter.
- The OIG is only looking for whether the provider met certain measures, while the CMS contractor reviews all of the measures for compliance.
These audits are real and part of the 2015 OIG work plan. To be prepared for the audit either by the CMS contractor or the OIG, it is important to maintain an audit binder containing at a minimum the following information:
- Printed reports from your ONC-certified EHR technology for each measure to which you attest
- Dated screenshots to show that you met Yes/No only objectives (i.e., those without reportable measures)
- Screen shots and explanations showing how you derived your clinical quality measures
- Information demonstrating that you met any applicable public health reporting objectives or qualified for an exemption
- Your dated and completed Security Risk Analysis and any related documentation
NextGen Physician Consulting offers audit assistance for responding to OIG or CMS meaningful use audits. For more information, please contact your NextGen Healthcare representative or visit the Meaningful Use Audits page on Knowledge Exchange. The page contains information on optional MU Audit Assistance as well as instructions for NextGen EHR clients to obtain a letter showing proof of access to certified EHR.