• CMS starts conducting EHR Incentive Program pre-payment audits

    Author | Date March 15, 2013
    As promised, the Centers for Medicare and Medicaid Services (CMS) is sending out letters informing a random segment of providers that their Medicare billing activities will be audited.  Eligible providers (EPs) and hospitals who attested in January of 2013 might find themselves under the microscope as CMS tries to ensure that meaningful use payments are going to the right people for the right reasons.
    “We have a fiduciary responsibility to make sure that we are paying appropriately,” explained Elizabeth Holland, Director of the HIT Initiatives Group at HHS during HIMSS13.  After widespread concern about questionable billing practices among providers vying for government funds – and accusations that CMS hasn’t been doing enough to combat fraud, the agency has ramped up its efforts to keep an eye on meaningful use participants.  And with budgets being slashed due to sequestration, every dollar counts for both CMS and providers, who can’t afford to take an additional hit due to auditing.
    Providers who have already received their incentive payments for January are safe, according to Holland, but anyone who’s missing a check should look in their mailboxes for a letter from Figliozzi & Co., the firm contracted by CMS to conduct its pre-payment investigations.  These pre-payment audits follow a round of post-payment inquiries started in July of 2012.  More than 2,000 post-payment audits are currently underway, some targeted due to flagged data, and others entirely random.  During these sweeps, CMS has found that some EPs can’t provide the documentation to support their attestation, prompting the agency to release additional guidance in the coming months.
    “EPs, eligible hospitals, and critical access hospitals should retain all relevant supporting documentation in either paper or electronic format, [including] documentation to support attestation data for meaningful use objectives and quality measures for six years post-attestation” the CMS audit fact sheet recommends.  “Documentation to support payment calculations (such as cost report data) should follow the current documentation retention processes.”  Audits by Figliozzi may include an on-site visit and a demonstration of the provider’s EHR system.  If the provider is found ineligible after a review, the payment will be recouped.  Providers who wish to appeal may do so, and the process will be handled by the provider’s home state.
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