EHR incentive recipients subject to audits, CMS says

September 24, 2012

Health care practitioners who receive Medicare or Medicaid electronic health records (EHR) incentives are subject to a new auditing program designed to ensure they have met the qualifications for the bonuses, according to the AOA Third Party Center.

Practitioners who attest compliance with federal EHR incentive programs should therefore retain all relevant supporting documentation in either paper or electronic form, advises Stephen Montaquila, O.D., AOA Third Party Center Executive Committee chair.

Practitioners found to have been ineligible for federal EHR incentive bonuses in post-payments audits will be required to return payments or have their future Medicare payments docked, Dr. Montaquila emphasizes.

The U.S. Centers for Medicare & Medicaid Services (CMS) announced a number of new pre-and post-payment auditing programs over recent months, but has not widely publicized the EHR incentive audits, AOA Advocacy Group staff noted.

As a result, some EHR incentive recipients have been taken by surprise when receiving audit notices, according to published reports.

EHR incentive recipients selected for audits will receive a letter asking them for:

  • A copy of the document certifying the provider’s EHR technology as eligible for the incentive program.
  • Supporting documentation for a provider’s claims to have satisfied mandatory meaningful use objectives and measures, such as electronic prescribing, and
  • Supporting documentation for a provider’s claims to have satisfied elective (so called “menu”) meaningful use objectives and measures.

Medicare EHR incentive payment audits are being performed by Figliozzi & Company, a certified public accountant firm in Garden City, N.J., under a contract issued by the CMS in April. Medicaid EHR incentive audits will be conducted by the CMS and state Medicaid programs.

The accounting firm said the audit letters are being sent to a fairly large sample of EHR incentive recipients, some selected at random and some specifically targeted.

A spokesperson for the accounting firm acknowledged to the online health care news service Medscape last month that the letters are not highly specific. However, the firm believes practitioners will understand that they are being asked to provide documentation of compliance with the 20-plus mandatory and menu meaningful objectives that have been established for the federal EHR incentive programs.

The auditors believe most practitioners with adequate recordkeeping systems will be able to produce the required documentation.

To be prepared for an audit, the AOA Third Party Center suggests practitioners save all supporting electronic or paper documentation that supports their attestation for EHR incentives in either paper or the electronic format used in the CMS’ online attestation process.

That includes records documenting compliance with Clinical Quality Measure objectives, the AOA Third Party Center emphasized.

Documentation to support the attestation should be retained for six years post-attestation, the AOA Advocacy Group noted.

Appeals processes for the auditing program will be established, according to the CMS.

The CMS plans to post additional information at www. cms.gov. Practitioners seeking information on the Medicaid EHR audits programs should contact their state Medicaid agencies, CMS officials said.

Additional information on the documentation necessary to demonstrate compliance with federal EHR incentive program standards can be found at http://tinyurl.com/bvxkrh7 or www.aoa.org/ehr.


  1. […] However, the agency has no way to confirm at the time of attestation that a practitioner has actually met the required utilization criteria. (See “EHR incentive recipients subject to audits, CMS says,” AOA News, September 2012 at http://newsfromaoa.org/2012/09/24/ehr-incentive-recipients-subject-to-audits-cms-says.) […]

  2. […] to conduct Medicare Electronic Health Record (EHR) incentive program payment audits. As the AOA previously reported, Medicare EHR incentive audits began in 2012. In addition to post-payment audits, the CMS […]

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