Is that an audit in your pocket, or are you just glad to see me?
We knew they would be coming. We just weren’t sure how and when audits related to the CMS EHR Incentive Programs would first appear. Well, we still don’t know much about the Medicare audits, but details of the Medicaid audit process are starting to dribble out.
A report from the Office of Inspector General to CMS provides a bird’s eye view of what 13 states are planning for Medicaid EHR incentive eligibility audits. The various State Medicaid agencies are responsible for their own Medicaid EHR incentive programs as well as the integrity of the proper disbursements to eligible professionals and hospitals. The report states that of the 13 states in the report: “all 13….reported that they plan to verify at least half of the eligibility requirements prior to making EHR incentive payment…..In addition, all States plan to audit eligibility requirements after payment”.
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One interesting aspect of this report is that it only addresses the review of how, and to what degree, these States intend to verify a provider or hospital might be eligible for the Medicaid incentives based on percentage thresholds and volumes. The issue of whether an Eligible Professional or Eligible Hospital that meets the eligibility requirements for Medicaid also meets ‘meaningful use’, and how that will be audited, is not addressed. However, since the verification of eligibility varies from state to state, we can assume the same level of variation could exist for the auditing of meaningful use.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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