Figliozzi and Company Meaningful Use Audits of health care providers that attested to Meaningful Use for Stage 1 are being led by Figliozzi and Company, the  CMS designee to perform audits for the EHR Incentive Program (the “Program” or “Meaningful Use Program”).  The letters are requesting  records related to the attestation by Eligible Providers (“EP”).  The American Recovery and Reinvestment Act (ARRA) provides statutory authority for these audits.  See Meaningful Use Audit Defense.

Despite  recent writings by some law firms, a failed Meaningful Use audit (“final determination”) by Figliozzi is a serious affair,  requiring the attesting organization to immediately pay 100% of the Meaningful Use incentive funds back to CMS.  For a $500 million hospital system, for example, this is likely to be $millions.

The letters from Figliozzi and Company may request:

  • A  copy of the Eligible Provider’s certification from the ONC for the technology they used to meet Meaningful Use Stage 1.
  • Documentation to support the observation method chosen (observation services or all emergency department visits).  This method is used in determinations of which  which patients were included in the denominators of meaningful use core and menu items.
  • Supporting documentation for the attestation module Core Measures and Objectives.
  • Supporting documentation for the attestation module responses as to Menu Set objectives and measures.

A meaningful use audit defense strategy would include being prepared to demonstrate in-depth inquiries regarding structured, discrete data.  In addition, audited entities should be prepared to discuss all Core Measures including Computerized Physician Order Entry (CPOE), drug interaction checks enabled, problem lists, and other areas such as CQM and discharge.  Also, up to five Meaningful Use Stage 1 Menu Items and 15 clinical quality measures.

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