EHR Alert

Providers that receive Electronic Health Record (EHR) incentive payments for participation in the Medicare or Medicaid EHR Incentive Programs may be subject to audits. CMS wants to make sure that the information providers provide and attested to is accurate and meets the thresholds established in the programs guidelines.  The audit can take place either before or after providers receive an incentive payment. Preparing in advance for these potential audits by saving the required documentation will make the process easier. The auditors will want to see ALL relevant detailed supporting documentation (in either paper or electronic format) that was used in completion of the Attestation Module responses. Providers must make sure the information is dated, the time period covered is documented, and that there is evidence to show that the report belongs to the provider for the providers EHR location.

According to CMS, it is the provider’s responsibility to save documentation that fully supports all data submitted during attestation. The reason is that an audit can include a review of any documentation needed to support the information in the attestation including documentation that demonstrates how data was accumulated and calculated, and to support each measure attested to, and any exclusions claimed by the provider.  This could even include a review of medical records and patient records.

Upon completion of an audit, an audit determination letter will be issued informing the provider whether or not they were successful in meeting meaningful use of electronic health records. If a provider is found not eligible, based on the audit, the payment will be recouped. Besides recouping payments, CMS may pursue additional measures against providers who attested fraudulently to receive an EHR incentive payment.