Health Care Information Consultants, LLC

Meaningful Use Pre-Payment Audit

Jennifer Moore, MHA PrincipalMay 16, 2014

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The Prepayment Audit Letter

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The Instructions• Please supply all requested items by January 27, 2014 by utilizing one of the

following methods: 1. Electronically uploading the information to our secure web portal (see step by step

instructions attached) 2. Mailing the information to: Figliozzi & Company, CPAs P.C. 585 Stewart Avenue Suite 416 Garden City, NY 11530 The contracts between CMS and its contractors contain a confidentiality of information

clause that state propriety information or data submitted by or pertaining to an organization cannot be released without the prior written consent of the organization. Additionally, the contractors are required to obtain written permission from CMS’s contract officer whenever the contractor is uncertain on the proper handling of material under the contract. Further, if any information contained within the records your organization submits to CMS’s contractors constitutes confidential information, as such terms are interpreted under the Freedom of Information Act (FOIA) (5 U.S.C. § 552) and applicable case law, CMS will protect such information from release when requested under FOIA in accordance with the Department of Health and Human Services regulations (45 C.F.R. § 5.65 (c)).

If you have any questions, please contact your assigned auditor, which can be found in the body of the email.

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The Data Request

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Where to Begin?• Hopefully the documentation/evidence of our attestation began

long before we received this letter

• But the first thing we did was confirm the validity of the request by contacting Figliozzi

• Next we reviewed the documentation from the attestation itself

• We began to pull together the documents that we were going to upload to their site.

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What was in our Evidence Book for the Threshold Measures?

• The CMS spec sheet for the measure• Print out of any FAQs that we used to make our assumptions,

workflows and attestation• Workflow or procedure documentation used for each of the measures • Our self audit work papers:

– Procedure for report validation– randomized record reviews for each measure that validated the report

positive or negative for denominator and numerator inclusion/exclusion– Screen prints from the EMR

• Weekly tracking reports for PI and procedure for how we used them• Letter from vendor confirming our license and productive use of

certified product during the attestation period• Final EMR reports used to enter numerators and denominators into the

CMS Attestation Program

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What Else Did We do?• Went to the files and found license agreements, POs and invoices

• Had additional requests for corrected information– The auditors do a quick look so label, label, label!

• When we felt they were misunderstanding our data we asked to speak with the boss

• Used this time to review all documentation for the attestation

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What to do if we had determined we had made an error in attestation