Meaningful Use Attestation Process and EHR Incentive Audits

This article was posted December 13, 2011 by Jim Tate

Meaningful Use Attestation: A Word to the Wise

The CMS EHR Incentive Program is going full bore. Over $390,000,000 was paid out in November alone by Medicare to Eligible Professionals (EP) and Eligible Hospitals (EH). That doesn’t even include the Medicaid incentives. Seems like every possible EHR is certified, EPs and EHs are registering, and we’ve seen the Stage 1 early 2011 adopters be given a present of not having to reach Stage 2 until 2014. With everything humming along, what could go wrong? Certification, registration, meaningful use, attestation, incentives. Where is the fly in the ointment? Well just don’t forget the potential audits.

CMS clearly states that there will be audits: “All providers attesting to receive an EHR incentive payment for either Medicare of Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format used in the completion of the Attestation Module responses). Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.” CMS even tells us how to prepare for an audit: “To ensure you are prepared for a potential audit, save the supporting electronic or paper documentation that support your attestation. Also save the documentation to support your Clinical Quality Measures (CQMs). Hospitals should also maintain documentation to support their payment calculations.”

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