Hospital Electronic Health Records (EHR)
Numerous governmental organizations and politicians have grumbled over the lack of oversight for electronic health record (EHR) incentive payment programs. In light of these issues and others—including the impending end of scheduled funding for the EHR program—audit processes already have begun. An eligible hospital (EH) can have several different EHR audits going on at one time—Medicare HITECH audits, Medicaid prepayment audits, Medicaid AIU audits, Medicaid post-payment audits, Meaningful Use (MU) audits, Federal OIG audits, etc. Any of these audits can be a huge undertaking and have significant negative effects on incentive payments.
BKD’s EHR team can help EHs through these audits. We understand the aggravation and time loss each of these audits can cause, and we’ve developed services that can help EHs find additional dollars and, more importantly, keep them. Our EHR consulting services show EHs someone is on their side to help them through these potentially overwhelming audit processes.
Meaningful Use Audit Assistance
EHs that fail an MU audit will be required to pay back, within 30 days, any Medicare and/or Medicaid incentive payments received for that program year. Failing an MU audit also triggers an automatic MU audit for the subsequent year and all preceding MU attestations before the failed program year.
We have helped more than 50 EHs through actual MU audits. That experience lets us help EHs keep their valuable incentive payments and avoid these multiple audits. BKD has been extremely successful in helping hospitals develop mitigating strategies and solutions to pass an MU audit. We help EHs in all stages of the MU process: gathering and reviewing requested MU audit documentation, packaging supporting documentation into the format MU auditors prefer, helping with mitigating strategies for answering MU auditor questions after the supporting documentation has been submitted or assisting with the CMS appeals process for an EH that already has received notification of failure.
Meaningful Use Documentation Analysis (MUDA)
- EHs receiving negative determinations will owe CMS the entire EHR incentive payment for Medicare and/or Medicaid for the program year under audit. Failure in this type of audit due to lack of appropriate documentation can be avoided, which is why BKD provides MUDA service. One of the main reasons EHs fail MU audits is the different schools of thought between the information technologists gathering the data and the auditors (or CPAs) requesting and reviewing the data. Our experience helping EHs through actual MU audits has let us develop an understanding of the supporting documentation MU auditors typically accept. In addition, we can help uncover and correct potential issues before they lead to recoupments. This service also offers peace of mind to EHs not currently under MU audit.
Medicare & Medicaid Attestation Assistance
- BKD can guide EHs that have not yet attested to the Medicare or Medicaid EHR incentive programs through the entire process with step-by-step instructions and live online technical support. Our team can assist with the subsequent-year attestations throughout both EHR program processes. That way, your EH will know exactly which MU stage it should attest to, when it can attest, what important dates are approaching or what penalties may await.
Medicare & Medicaid EHR HITECH Payment Audits
- BKD can help EHs before or during an EHR HITECH incentive payment audit from Medicare, Medicaid or the OIG.
- Medicare HITECH payment audits are conducted by the EH’s Medicare Administrative Contractor; every EH will have each EHR settlement audited at some level.
- Medicaid HITECH payment audits are conducted by outside vendors that contract with individual states and are subject to audits based on each state’s CMS-approved HITECH plan.
- The OIG has said EHR is a high priority on its workplan for coming years and has the freedom to audit both Medicare and Medicaid—and potentially even the MU side.
- These audits review each variable in the EHR formulas as well as the supporting documentation for those variables. Based on their findings, auditors can make adjustments that lead to EHR recoupments. Our team will look for the potential positive adjustments through this audit process that can help offset potential negative adjustments made during the HITECH audit. Our team takes a very detailed look, outside the scope of the cost report, at EHR variables to search for additional incentive dollars. Two key areas heavily reviewed by the auditors are charity care and Medicare/Medicaid days. BKD assists EHs with both of these issues, in addition to other areas often overlooked during these audits.
Medicare & Medicaid Settlement Review & Day Analysis
- BKD has extensive experience assessing Medicare & Medicaid incentive payments to evaluate whether facilities have received appropriate EHR incentive payments or if there are any potential unforeseen risks that could be detrimental to the facility. This assessment offers deeper analysis of what goes into the EHR calculations and a more detailed view of the variables used in the EHR calculation for incentive payment programs. BKD has helped more than 250 EHs nationwide recover $145 million in additional incentive dollars.
Great Plains Health Alliance (GPHA)
"BKD has an excellent understanding of our organization, so its advisors are able to bring solutions of which GPHA may not have been aware. Case in point: BKD assisted our hospitals in enrolling in the Medicaid EHR program. The BKD team identified the incentive program, informed and communicated with our hospitals, used cost report data to yield greater savings and completed the project in a timely manner."
— Dave Dellasega, Chief Executive Officer
Great Plains Health Alliance (GPHA)
Blanchard Valley Health System
“After having a long-term relationship with a Big Four Accounting firm, we had very high expectations for BKD right from the start. I’m happy to say that they’ve exceeded our expectations. BKD’s people from partner to staff are knowledgeable, professional and experienced in serving hospitals of our size and complexity. We have benefited significantly from their industry experience and technical knowledge. As promised, BKD has provided a high level of partner involvement and a consistent team of auditors and advisors who focus on the areas of our business that are material to our financials. They know Health Care and are reliable and responsive to our needs. Engaging BKD was the best decision we could have made. We truly value this relationship and are looking forward to working with BKD for a long time.”
— David Cytlak, CPA, Chief Financial Officer
Blanchard Valley Health System