Stage 1 EHR Incentive Pre-Payment Audits Begin

Last July some eligible professionals (EPs)  that attested to Stage 1 Meaningful Use and received their EHR incentive check began to receive audit letters from CMS’ designated the accounting firm of Figloiozzi and Company.  Now a certain percent of EPs who have implemented and attested to Stage 1 meaningful use may be subject to a pre-payment audit process.

According to Elizabeth Holland, director of CMS’ Health IT Initiative Group, and as reported by AAFP, between 5 to 10 percent of all eligible professionals attesting for meaningful use will be selected for prepayment audits. “Selections will be made both randomly and also based on protocols that identify suspicious or anomalous attestation data,” said Holland. “Postpayment audits will affect another 5 percent to 10 percent of physicians and other health care professionals. The scope of both audit programs is consistent with the scope of audit strategies for similar CMS programs.”

Overview of the CMS EHR Incentive Programs Audits – CMS FAQ

All providers attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses.  Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.

Preparing for an EHR Incentive Programs Audit – CMS FAQ

To ensure you are prepared for a potential audit, save the electronic or paper documentation that supports your attestation. Also save the documentation that supports the values you entered in the Attestation Module for Clinical Quality Measures (CQMs). Hospitals should also maintain documentation that supports their payment calculations. Upon audit, the documentation will be used to validate that the provider accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.

CMS makes available an FAQ overivew and anFAQ factsheet related to the EHR incentive programs.