Think the chances of getting a meaningful use audit are slim? Tell that to the folks who lost their job for doing it wrong, or folks at the four-hospital Scripps Health, who, all told, have undergone 11 meaningful use audits to date.

Tony Panjamapirom, consultant at The Advisory Board Company, said successfully preparing for -- and surviving -- an audit also comes down to seeing audits as a "serious need, rather than a threat."

At the end of the day, he pointed out, proper preparation can save a healthcare provider or hospital money, as it can help protect or defend incentive payments in addition to preventing payment adjustments. It can also potentially save your job.

Panjamapirom cited the case of Detroit Medical Center's Chief Medical Information Officer Leland Babitch, MD, whose employment was terminated after it was discovered the hospital could have to pay back a potential $14 million in EHR incentives. Ultimately, auditors concluded the hospital was not at fault and would not be required to pay back any incentive money, but the damage had already been done.

"My name was at the bottom of those attestations," said Babitch, speaking at a HIMSS physician's symposium back in March 2013. "The biggest unintended consequence of meaningful use, in my instance, was that I lost my job."

In another case, Health Management Associates – which operates 71 hospitals – back in November, announced it was returning $31 million in improperly claimed electronic health record incentive payments, for hospitals that did not meet meaningful use requirements as originally claimed.

That September, both HMA's chief financial officer and senior vice president of finance announced their resignations, which were also a result of earlier criticism over their handlings and questionable financial practices.

Although financial error was discovered via an internal review, Panjamapirom pointed out this would have undoubtedly come up in a meaningful use audit as well, had the company not discovered the discrepancy first.

Another incident is what transpired at Shelby Regional Medical Center in Texas earlier this year. The former chief financial officer at the hospital was charged with healthcare fraud violations after falsely attesting to CMS for meaningful use incentive payments. The hospital received $785,655 in wrongfully claimed payments.

This, as Panjamapirom said, appeared to be more of a deliberate case, but nonetheless all these details would emerge if say, a meaningful use audit headed their way.

And these audits are expected to increase.

"We could expect from these activities that the vigor and the frequency of the meaningful use audit will increase," said Panjamapirom.

"After you hit the submit button for attestation, the auditor can come knock on your door at any time before or after you received the incentive payment, and remember that they can audit you up to six years. It's critical because it determines how long you need to keep your support documentation in place."

Doing it right: conducting a mock audit

The four-hospital Scripps Health in California, who has undergone 11 meaningful use audits to date, say proper preparation proves integral to survival. 

At least one in 20 MU attesters will undergo a meaningful use audit, of which 50 percent will undergo a pre-payment audit, according to the Centers for Medicare & Medicaid Services.

"We've had prepayment audits. We've had post payment audits, and we've had those CMS mini audits," said Joanne La Grange, director of the meaningful use program at Scripps, speaking to a HIMSS14 audience.

Add to this the fact that all 11 of these audits have occurred in the last nine months. "Auditing is escalating," she added, and it's a serious time and resource commitment, so best be prepared, which is why she and her Scripps team conduct mock audits to ensure their house is in order come time for the real deal.

"This gives you an opportunity to develop a systematic approach so that you can respond in a timely manner," added La Grange, who said Scripps was given four weeks for post/pre-payment audits and two weeks for the limited audits.

[See also: Preparing for a meaningful use audit.]

Thus, the first step of developing a successful mock audit comes down to creating a book of evidence, which needs to be developed prior to attestation. This "book," La Grange pointed out, should be stored on a secure device with limited access. Part of this step involved systematically organizing folders and using different media types, like recorded demonstration.