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OIG Estimates $729.4M in Erroneous EHR Incentive Payments

OIG estimates 12 percent of the total Medicare EHR incentive payments issued to EPs between 2011 and 2014 were made incorrectly.

EHR Incentive Payments

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- CMS overpaid an estimated $729.4 million in Medicare EHR incentive payments to eligible professionals (EPs) who failed to meet meaningful use requirements, the Office of Inspector General (OIG) recently announced.

In a report published Monday, the federal agency stated 12 percent of these EHR incentive payments to eligible professionals should not have been paid.

The review included 485,499 Medicare EHR incentive payments made to 250,470 eligible professionals from 2011 to 2014.

“These errors occurred because sampled EPs did not maintain support for their attestations,” stated the report. “Furthermore, CMS conducted minimal documentation reviews, leaving the self-attestations of the EHR program vulnerable to abuse and misuse of Federal funds. “

CMS also overpaid EPs approximately $2.3 million as a result of providers switching between Medicare and Medicaid incentive programs.

“These errors occurred because CMS did not have edits in place to ensure that EPs who switched from one program to the other were placed in the correct payment year upon switching,” stated officials.

In an effort to mitigate the financial impact of these errors, the federal agency stated CMS should recover the $291,000 in erroneous payments issued to sample eligible professionals that failed to meet meaningful use requirements.

Additionally, CMS should more carefully review eligible professional incentive payments and find which providers unsuccessfully attested to meaningful use measures for each program year in an effort to begin recovering the nearly $730 million in inappropriate payments.

Officials also suggested CMS review random samples of documentation submitted by eligible professionals for self-attestations to indicate areas where inappropriate payments may have been made following the audit period.

The report also states CMS should educate eligible professionals on proper federal HER documentation requirements to recover the 2.3 million in overpayments to providers switching programs.

Finally, officials stated CMS should begin edits within the National Level Repository system to bar eligible professionals from receiving payments under both EHR incentive programs for the same program year.

In response, CMS agreed with the majority of OIG’s recommendations and stated its intentions to implement targeted risk-based audits to strengthen program integrity into 2017.

OIG reviewed this feedback from CMS and determined targeted risk-based audits would not be enough to capture the kinds of data errors identified in the report.

“We therefore continue to recommend that CMS review EP incentive payments to determine which EPs did not meet meaningful use requirements and attempt recovery of the estimated $729,424,395, as well as review a random sample of EPs’ documentation supporting their self-attestations to identify inappropriate incentive payments,” stated the federal agency. 

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