Total federal incentive payments for the use of electronic health-record systems have soared to just over $2.5 billion, according to CMS. Over 114,000 eligible professionals and hospitals have registered for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. These facts and figures are showing exceptional growth in adoption and implementation of certified EHR technology. Thus far, every step (registration, Meaningful Use measures, attestation, and EHR incentive payments) is going as smoothly as intended. What every provider needs to know is that any provider attesting to receive an EHR incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program potentially may be subject to an audit. The audit is to ensure that information exchanged is accurate; financial details are matching, and report of clinical quality measures (CQMs) is generated as output from an identified certified EHR technology.
CMS is scrutinizing inaccuracies in eligibility, reporting and payment through pre-payment edit checks and post-payment audits. Even if the provider received incentive payments and later on officials from CMS find out during audits that the provider is not qualified for the incentive, the payment will be recouped. To reclaim that, there will be an appeal process for the providers to prove eligibility in such a case.
Auditors would examine that eligible providers (EP) and eligible hospitals (EH) are properly using a certified EHR system and validate that the provider(s) accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.
Make packets of documentation used in attestation for each year of participation.
CMS requires that all providers should retain documents (electronic or on paper) used in attestation for up to six years. It means that providers registering for attestation now are liable to audit anytime in the coming six years. To foolproof this looming audit, providers should compile packets of documentation used in attestation for each year of participation. If saving it electronically, they should be in damage resistant formats i.e. PDFs or image file formats. It is better to print them on paper as well and archive them annually. Furthermore, it is quite advantageous if your EHR system is capable of managing revenue cycle and payments. CMS auditors would be eyeing financial data as well so as to testify that incentive payments are made on justified financial calculations.
Maintain an audit checklist.
To streamline the process, maintaining an audit checklist is quite a pragmatic approach, counter checking clinical work practices on weekly bases or examining the tasks processed through an EHR system that passed the 90 day attestation period for the first year. The checklist should ensure that the EHR system is meeting Meaningful Use measures i.e. recording demographics, vital signs, smoking status, etc., and fully utilizing the eRx/CPOE/CDSS functionalities. Similarly, clinical quality measures are rightly achieved and patients’ health information is exchanged on HIPAA transaction standards.
CMS is going to implement the audits through third party contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers. As for audits on Medicaid providers, CMS, in addition to its contractors and States, and their contractors, will perform the audits. Regarding the appeals process, for Medicare, CMS and states will manage the processes, while States will implement appeals processes for the Medicaid EHR Incentive Program. For more information about the Medicaid appeals, please contact your State Medicaid Agency. Nothing should be left for the eleventh hour, EPs and EHs should have periodic internal audits which can point out malpractices in advance.