Reducing the risk of a CMS Meaningful Use Audit
The “Red Flag” / How to avoid1. Unique Patient Denominator inconsistencies
· on measures which require “unique patients seen by the EP” / The denominator should be the same for Core Measures #3, 5, 6, 7, Menu Measures #5, 6
2. Subsets of “Unique Patient Denominator”
· with denominator higher than denominator for unique patients / The denominators for Core Measures #1, #8, #9 and Menu measures #4, #7, #8 should be = to or < than denominator used in Core Measure #3
3. Subsets of “Unique Visits Denominator”
· with denominator lower than denominator for unique patients / The denominator for Core Measure #13, should be > denominator for Core Measure #3, as typically some unique patients have more than one visit during reporting period.
4. Measures counting patients outside of
Certified EHR with denominator less than
similar denominators with only records in
EHR / During attestation, the provider has the opportunity to indicate source of data for those measures (i.e., for all patients or for EHR derived data only)
5. Submitted denominators differ significantly
from data at disposal for Medicare/Medicaid / Attempt to enter every patient’s visit in the EHR. If you are paid on 500 Medicare claims but only have 200 as your denominator for total visits (i.e., Core #13) this would raise a red flag (are you really achieving MU if less than ½ of your visits are done in the EHR?)
6. Improper exemptions taken / Do not mark “Yes” on exemptions inconsistent with the practice’s scope of practice and location
7. Reporting Zeros in numerator for measures / Some practices may be forced to report zeros on some measures (particularly on Clinical Quality Measures) due to scope of practice or vendor limitations. However, if possible, avoid reporting zeros.