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“The government will try to take the money back any way it can. It’s disheartening to be accused of fraud, and the audit experience has left a sour taste in our mouth.”


how I determined the numerators and denominators used to attest and specific diagnostic codes used in a certain time period,” she said. She encourages physicians attesting to meaningful use to save all documen- tation related to the attestation process, including emails. Atul Sachdev, MD, a Baytown solo family physician, attested to Stage 1 meaningful use under the Medicare incentive program in February 2012 and received $18,000 for doing so. Ten months later, however, the audit notifi- cation email he received from Figliozzi shocked him. “My initial reaction was that I had done something wrong. Being notified of an audit of any nature doesn’t leave you with a pleasant feeling,” Dr. Sachdev said.


Initially, Figliozzi gave Dr. Sachdev two weeks to submit the following docu- mentation to prove he had met Stage 1 meaningful use criteria:


which is negotiated on a client-by-client basis,” Ms. Sanchez said. Any physician who has received a meaningful use incentive payment is fair game for an audit. If Figliozzi’s efforts are fruitful, the government could po- tentially recoup a substantial amount of money from physicians nationwide. CMS paid $12.65 billion through February in meaningful use incentive payments to Medicare- and Medicaid-eligible profes- sionals and hospitals. “The government will try to take the money back any way it can. It’s disheart- ening to be accused of fraud, and the au- dit experience has left a sour taste in our mouth,” Dr. Flores said. At press time, CMS hadn’t recouped meaningful use incentive payments from any Texas physicians. CMS has an appeal process for physicians found ineligible for payment following an audit. Con- tact the CMS EHR Information Center at (888) 734-6433, Monday through Friday, for information on filing appeals. Robert Anthony, deputy director of the HIT Initiatives Group at CMS, said the agency expects to audit about 5 per- cent of participants in the Medicare and Medicaid EHR incentive payment pro- grams. Without being specific, he added


32 TEXAS MEDICINE June 2013


that a few health professionals had re- ceived adverse-finding letters from CMS that indicated they were ineligible for meaningful use payments and had be- gun the appeal process. Additionally, the Texas Health and Human Services Commission (HHSC) hired the accounting firm Davila, Bus- chhorn & Associates, PC, to conduct meaningful use audits in the Medicaid EHR incentive program. At press time, TMA hadn’t heard from any Medicaid- participating physicians selected for an audit. For information on Medicaid meaningful use audits, contact Texas Medicaid & Healthcare Partnership at (800) 925-9126, option 4.


Audits, round two After Dr. Wolf submitted the necessary documentation to Figliozzi in December, the firm sent her another letter in March informing her that, upon review, she hadn’t met meaningful use criteria and had seven days to submit additional doc- umentation. Dr. Wolf called the auditing firm and received a two-week extension. “The second time I had to submit doc- umentation required a lot more work. The auditor wanted more specific in- formation like audit trails that showed


• Proof that he had a certified EHR technology (CEHRT) system via cop- ies of licensing agreements or vendor invoices;


• Answers to questions on the number of facilities used to see patients and the CEHRT system used at those fa- cilities;


• Proof that more than 50 percent of patient encounters occurred where the CEHRT system is used;


• Proof that more than 80 percent of patient encounters are maintained in a CEHRT system; and


• Supporting documentation for all core set and menu set objectives, en- suring the EHR logo is shown in gen- erated reports or step-by-step screen- shots show the EHR logo.


Dr. Sachdev quickly gathered the doc- umentation and turned it in to Figliozzi two days after the request. He says he didn’t hear from the auditor for three months, when he received a follow-up email in March notifying him that the company found his documentation in- adequate. This time the auditor gave the physician seven days to provide the fol- lowing documentation:


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