EHR Audits Q&A
With the news that CMS has started conducting pre-payment audits to monitor meaningful use payments, some providers have been worried about what it means if they get a letter in the mail. Rob Anthony, Deputy Director of the HIT Initiatives Group, Office of E-Health Standards and Services at CMS, sat down with EHRIntelligence to discuss how CMS is handling its audits of potential meaningful users, and to give some tips to providers about what to have on hand if an auditor comes knocking on the door.
What’s the purpose of meaningful use audits, and how do they help CMS and providers?
As a government agency, we do an audit for anything where we’re disbursing funds. We obviously want to be sure that the right people are getting paid who should get paid, and that people have done what they said they did. So we take the oversight of the payment pretty seriously, and a robust audit program is really an essential component of that oversight. And really, the purpose of the audits is partially to detect inaccuracies in things like eligibility or reporting and payment information, ensuring that the providers who are participating in the Medicare EHR Incentive Program are only receiving payment if they successfully demonstrated meaningful use and met the other program requirements. But also, as we’re moving into years where the payment adjustments take effect, we’re moving into a time where providers, if they’re not meaningful users, will receive payment adjustments. So we want to ensure that, as we move forward, everybody who is actually attesting to meaningful use is really a meaningful user so that they can avoid those adjustments moving forward. Incentives are great, but we want to make sure that people aren’t subject to those payment adjustments when they don’t have to be.
The OIG made some strong recommendations last year about how CMS should improve their oversight of EHR Incentive Payments. How are you addressing these concerns?
We’ve instituted the pre-payment audit program, after initially only doing post-payment audits. It should be noted that at the time the OIG report was initially compiled, we really were at the very beginning of our audit program. We were really just establishing the audit protocols that we use to determine what documentation to ask for, what to look for, and how we go out and talk to providers, so we really didn’t have a developed audit program at the time those recommendations were released. As we have moved forward, I think that we have been able to really figure it out. We do both random and targeted audits, and we’ve figured out the type of things that are anomalous and raise a red flag for us to start taking a look at, so that allows us to be much more robust in our oversight. And now, with the introduction in January of the pre-payment audits, we’re doing that random and targeted check of providers to look at their attestation before they actually receive payments. We think that appropriately addresses the OIG recommendations.
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