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Stage 1 Meaningful Use Attestation Audits

CMS: Meaningful Use Audits Begin
Some healthcare providers that have attested to Stage 1 Meaningful Use have begun to receive letters. Though not officially announced, HHS has designated the accounting firm of Figloiozzi and Company to begin auditing. Figliozzi has operated in the healthcare industry since 1987 and specializes in Medicare compliance audits.
On the attestation page, CMS makes it clear that any provider attesting to receive EHR incentive payments for either the Medicare or Medicaid program may be subject to audits and lists what providers need to know to be prepared:

  1. All providers attesting to receive an EHR incentive payment for either Medicare or 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.
  2. CMS and its contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers. 
  3. States and their contractors will perform audits on Medicaid providers. 
  4. CMS and states will also manage appeals processes. 
Providers who received a letter were asked to provide the following:
  • Documentation from the ONC showing that the provider used a certified EHR system for meaningful use attestation
  • Information about the method used to report emergency department admissions
  • Documentation that the provider has completed attestation for the core set of meaningful use criteria
  • Documentation that the provider has completed attestation for the required number of menu set meaningful use objectives

According to the law firm of Ober | Kaler, an amended version of the audit letter has been sent out “clarifying that the audit letters seek additional detailed information but are not, at this time, requesting identifiable or detailed patient records.” The audit letters provide EP’s and hospitals little time to respond, a two-week response time is specified.

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