MU audit alert: 6 things you should do before Dec. 31
Does your organization use the calendar year as its Meaningful Use (MU) attestation period? That means your reporting year is drawing to a close in just a few weeks.
Auditors require a time-stamped date on several items that you must complete during the reporting period. Not doing it before December 31 may put your organization at risk of failing a potential audit of its 2013 attestation.
If you haven’t already done so, here are six things you should do before December 31:
1. Complete a HIPAA Security Risk Assessment.
Not completing this task is the number one reason organizations receive audit failure notice.
2. Take a screenshot of the EHR version number.
To record which version you are closing the year out with.
3. Record transmissions of clinical data and results.
Some menu measures only require an attempted transmission and documentation of results (failed or successful). Screenshots of the submission and the status results will be useful documentation in the event of an audit. Requesting confirmation emails from the receiving parties where possible will further bolster your records.
4. Take screenshots that validate active functions.
These records will help validate that CDS, Drug-Drug, Drug-Allergy, and Drug-formulary functions were still active on the final day of the calendar year. An example screenshot of pop-up messages generated by these features will help prove they were both active and functional on the final day of the year.
5. Print out an example patient list by a specific diagnosis.
(Only relevant as menu measure 4 for eligible hospitals (EHs) and 3 for eligible providers (EPs).
6. Keep paper copies of all MU attestation reports.
Also be sure to record the CMS Number and the certification number upon attaining ONC certification, or CHPL. To bolster your audit records, take time/date stamped screenshots of those reports when they are displayed by the EHR. (While this step isn’t required by December 31, it’s a helpful tip for submissions.)
Taking these steps will help your organization prepare for an MU audit. To be clear, the ideas and tips provided within this post (or on our new Meaningful Use Audit group on ClientConnect) are suggestions between colleagues — not legal advice. For other helpful tips, read 8 things smart providers do to prepare for an MU audit.
On a related note, ONC and CMS recently issued a joint announcement related to the start of Stage 3 of Meaningful Use and new, voluntary interim certification rules, known as the “2015 Edition” rules. Please visit ClientConnect for additional information for physician practices and hospitals.
Do you have additional suggestions? Add them here, or join the conversation in our Meaningful Use Audit group on ClientConnect.