Think the chances of getting a meaningful use audit are slim? Tell that to the folks who lost their job for doing it wrong, or folks at the four-hospital Scripps Health, who, all told, have undergone 11 meaningful use audits to date.
Tony Panjamapirom, consultant at The Advisory Board Company, said successfully preparing for — and surviving — an audit also comes down to seeing audits as a “serious need, rather than a threat.”
At the end of the day, he pointed out, proper preparation can save a healthcare provider or hospital money, as it can help protect or defend incentive payments in addition to preventing payment adjustments. It can also potentially save your job.
Panjamapirom cited the case of Detroit Medical Center’s Chief Medical Information Officer Leland Babitch, MD, whose employment was terminated after it was discovered the hospital could have to pay back a potential $14 million in EHR incentives. Ultimately, auditors concluded the hospital was not at fault and would not be required to pay back any incentive money, but the damage had already been done.
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“My name was at the bottom of those attestations,” said Babitch, speaking at a HIMSS physician’s symposium back in March 2013. “The biggest unintended consequence of meaningful use, in my instance, was that I lost my job.”
In another case, Health Management Associates – which operates 71 hospitals – back in November, announced it was returning $31 million in improperly claimed electronic health record incentive payments, for hospitals that did not meet meaningful use requirements as originally claimed.
That September, both HMA’s chief financial officer and senior vice president of finance announced their resignations, which were also a result of earlier criticism over their handlings and questionable financial practices.
Although financial error was discovered via an internal review, Panjamapirom pointed out this would have undoubtedly come up in a meaningful use audit as well, had the company not discovered the discrepancy first.
Another incident is what transpired at Shelby Regional Medical Center in Texas earlier this year. The former chief financial officer at the hospital was charged with healthcare fraud violations after falsely attesting to CMS for meaningful use incentive payments. The hospital received $785,655 in wrongfully claimed payments.
This, as Panjamapirom said, appeared to be more of a deliberate case, but nonetheless all these details would emerge if say, a meaningful use audit headed their way.
And these audits are expected to increase.
“We could expect from these activities that the vigor and the frequency of the meaningful use audit will increase,” said Panjamapirom.
“After you hit the submit button for attestation, the auditor can come knock on your door at any time before or after you received the incentive payment, and remember that they can audit you up to six years. It’s critical because it determines how long you need to keep your support documentation in place.”
Date: April 9, 2014