CMS provides additional EHR incentive payment audit guidance

July 1, 2013

The Centers for Medicare & Medicaid Services (CMS) contracted with Figliozzi and Company 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 has initiated pre-payment audits based on attestations submitted during and after January 2013.

Doctors selected for both pre- and post-payment audits are requested to submit documentation.  The AOA has already made available information regarding how best to respond to an EHR incentive audit and CMS recently provided some additional practical advice for doctors who are audited. This information may be helpful to optometrists.

The CMS officials indicate that doctors who are audited should retain any information or data used when attesting to meaningful use, such as computer-generated meaningful use dashboard.

The  CMS also recommended doctors keep any such documentation in a form that can be provided or shipped to auditors. For example, CMS officials referenced the meaningful use objective that requires doctors to provide patients with an electronic copy of their health information upon request. The CMS noted some providers who receive very few requests for electronic copies of records will simply keep a notebook and record the requests received. The CMS indicated this type of protocol can be helpful as the documentation can be scanned and provided easily during an audit.

The CMS also encourages doctors who are audited to communicate directly with auditors over the phone if the doctor has any questions regarding the kind of information required to be submitted. The CMS also noted that miscommunication can sometimes occur when there are numerous emails exchanged between the auditor and the doctor.

Additional information regarding the documentation necessary to demonstrate compliance with federal EHR incentive program standards can be found at http://tinyurl.com/lv82bup. Practitioners seeking more information on the Medicaid EHR audits programs should contact their state Medicaid agencies.

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