When it comes to Meaningful Use, audits are an unavoidable reality. These tips will help ensure your practice is prepared if and when the dreaded audit letter arrives.
It’s an old proverb that an ounce of prevention is worth a pound of cure. So to translate that to the real world, if you know something is inevitably going to happen, the best offense is a good defense. In other words, prepare.
That’s the case when it comes to Meaningful Use audits.
Chris Zaenger, the principle of Z Management Group in Elgin, IL, has been a medical practice management consultant since 1981. He has seen the downside of not being prepared.
“We have found that you have to prepare like you’re going to be audited,” Zaenger says. “And who you assign to do that is important.”
Zaenger tells the story of an ophthalmology solo practice that insisted signing on with a particular healthcare software company because the practice was part of the North Shore Medical Center Group at Livingston Hospital in Chicago.
“They wanted to be part of the network in terms of the ability to communicate back and forth,” Zaenger says. There was no ophthalmologist on that system at the time that she went on it, so she had an opportunity to design her own templates and EMR.”
The practice office manager then went ahead and began implementing Meaningful Use protocols inside the system. Unfortunately, the system didn’t measure everything that was required for Meaningful Use Stage 1, so the practice did those manually and then stored them on the practice’s hard drive.
“When they got the audit letter, the practice manager went to pull the data for the three measures that were not kept on the network, but the hard drive crashed,” Zaenger says. “And they didn’t keep paper backups of any of the material.”
The practice failed the audit, and had to refund the money. Ouch!
“Make sure you print and have hard copies of everything, including what’s in the system, so in the event of an audit, and your system’s down, you’re not blank on the day they walk through the door,” Zaenger recommends.
Zaenger says it’s particularly important for physicians to be actively involved in preparing for Meaningful Use audits. But the reality is that too often the responsibility is pushed off to the practice or office manager.
“You need at least one physician champion in a practice to kind of take the reins,” he says. “But a lot of the time it gets dovetailed to a nurse or some mid-level in the office.”
What he recommends practices do is not only have physician leadership and involvement by the entire practice, but give staff some incentive. That means spreading around some of the dollars the practice receives for Meaningful Use participation.
“Give them some bonuses to participate in the process,” Zaenger says. “I have a family practice—two doctors and three mid-levels—that is very busy. They do Meaningful Use, and they report at a monthly staff meeting how they’re doing on the measures.”
It’s also important to involve someone who is information technology savvy, especially in the healthcare arena. That individual can, at the very least, get the risk assessment portion of the Meaningful Use audit done.
“The office manager can go through and fill in the blanks on the rest of it,” Zaenger says. “Those reports and the data they need to kind of compile are freely available on CMS’s web site.”
Zaenger cautions that, ultimately, practices are going to lose money on the back end if they’re not doing Meaningful Use, or participating in other programs like the Physician Quality Reporting System. He points out that Medicare is already taking money away from practices, and it’s going to increase to 9% by 2018.
“Are you ready for that?” he asks, rhetorically. “You’re going to make less and less per encounter, and commercial payers are paying less per encounter. So, you try to get your money on alternative innovative compensation models the best you can.”
And if your practice is going to lose nearly 10%, how much of an impact is that going to have?
“Are you going to plan for that, or are you going to trim your costs so you can deal with the fact that you’re never going to do [Meaningful Use]?” Zaenger says.
The bottom line, Zaenger says, is that Meaningful Use audits are a reality. They’re going to happen at some point.
“The government does like to give, and take away,” he says. “It’s called being budget-neutral. So if you’re not prepared, or if you’re missing a link somewhere and you do get your Meaningful Use money, don’t spend it.”