The American Academy of Family Physicians (AAFP) has sent a letter to Centers for Medicare & Medicaid Services (CMS) acting administrator Andy Slavitt, expressing concerns with meaningful use audits.
Specifically, the letter states that “auditors are causing undue hardship for family physicians with unreasonable and burdensome documentation requests...” This is despite the fact that many family physicians have implemented and use electronic health records (EHRs) in the full spirit of the meaningful use program, the letter attests. “They therefore have a reasonable expectation that the meaningful use financial subsidy would help offset the implementation costs and associated initial decrease in practice productivity.”
The letter, written by AAFP board chair Reid B. Blackwelder, M.D., says that when auditors demand that family physician practices produce documentation years after the fact, unreasonable burden is created. “This is especially burdensome for family physicians who have made changes to their practice or have been acquired by a larger healthcare organization,” the letter says.
Another concern, according to AAFP, stems from employed physician situations, since many employment contracts include a clause stating all Medicare payments are turned over to the practice. “This creates an issue when the practice received the meaningful use subsidy, but years later, the individual physician is held responsible for repaying the payment after a failed audit.”
The letter also calls into question the effectiveness, responsiveness, and expertise of the auditors, as well as saying that the program’s “all or nothing” nature means that missing one document may lead to a failed audit and a repayment of the full subsidy payment. In reality, says AAFP, the audit program does not appear to take into consideration the high likelihood that a failed audit can be caused simply by missing documentation rather than by not achieving the meaningful use requirements.
AAFP calls for increased transparency from the federal government regarding audit statistics including the number of audits and the failure rate. “It would be helpful to have a report on what documentation was missing from failed audits. That would enable eligible professionals to have a better understanding over the type and granularity of documentation required,” the letter says.
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