So now it’s audits of the incentive payment program under meaningful use. Given the program’s complexity along with some other issues noted in the article, it’s not surprising to hear that a lot of EP’s would be in trouble if there was an audit. The author gives some great advice closing out the article:
What can EPs do to lessen their risk moving forward? Well I’m not a lawyer, but this is what I would do: I would initiate a review of any already submitted attestations to make sure they are accurate, truthful, and backed up by documentation. Seek guidance if you are not absolutely sure you know what your are doing. If your review finds “problems” you will not be able to blame your vendor or anyone else. Contact the EHR Information Center (888-734-6433) and begin the process of amending the information that you have submitted, even if was for a 2011 attestation. If you did not meet the requirements for incentives you will need to return the incentives. Better to do that than have your practice embroiled in an audit process with an uncertain outcome.