AAOS Now

Published 11/1/2014

Meaningful Use: Preparing for an Audit

CMS provides tips for practices

Any provider who receives an electronic health record (EHR) incentive payment under either the Medicare or Medicaid EHR Incentive Program may be subject to a meaningful use audit. Medicare eligible professionals and dual-eligible hospitals will be audited both before and after incentive payments have been made. The following tips from the Centers for Medicare and Medicaid Services (CMS) can help orthopaedic practices prepare for a meaningful use audit.

Who may be audited?
Approximately 5 percent to 10 percent of all providers will face random as well as risk–profile-driven audits. Providers who exhibit suspicious or anomalous data could be subject to successive audits. Providers can be audited up to 6 years following attestation, so it’s recommended that practices keep audit-ready files available for each year that each individual provider attests for an EHR incentive payment.

Who is in charge of the auditing process?
CMS has contracted with Figliozzi and Company to perform the audits on Medicare and dual-eligible providers who are participating in the EHR Incentive Programs. States and their contractors will perform audits on Medicaid providers participating in the Medicaid EHR Incentive Program.

Medicaid providers should contact their state Medicaid agency for more information about audits for Medicaid EHR Incentive Program payments because the requirements vary from state to state.

What documentation is required to pass the audit?
Providers should save any electronic or paper documentation that supports attestation. This includes reports demonstrating reported values, payment calculations, and evidence that the report was generated for a specific provider identified by a National Provider Identifier (NPI) or CMS Certification Number (CCN). Documentation to support attestation data for meaningful use objective and clinical quality measures should be retained for a minimum of 6 years after attestation.

What is the appeals process?
CMS has an appeals process for eligible providers and eligible hospitals that participate in the Medicare EHR Incentive Program. Providers may contact the EHR Information Center through a toll-free number, 888-734-6433, between 9 a.m. and 5 p.m. EST, Monday through Friday, for general questions on how to file appeals and the status of any pending appeals.

States will implement appeals processes for the Medicaid EHR Incentive Program. Medicaid program participants should contact their state Medicaid agency for more information about these appeals.

What is the 2014 CEHRT Flex Rule?
CMS released a final rule in September 2014 allowing certified EHR technology (CEHRT) flexibility. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014. In 2015, the Medicare and Medicaid EHR Incentive Programs will require all eligible professionals, eligible hospitals, and critical access hospitals to use the 2014 Edition CEHRT.

Additional Information: