Perhaps it was a bit anti-climatic when the flood gates opened. After over two years of angst and confusion the first CMS Medicare EHR Incentives began quietly arriving in May. This followed the first Medicaid incentives that began in January. CMS reported that by the end of April 40,000 EPs had registered for the Medicare program with an additional 2,000 registering for the Medicaid program. Over 10,000 EPs are registering every month. Gone are the nay sayers who claimed there would be no incentives. Gone are those voices that confused the CMS EHR Incentive Programs with the healthcare reform legislation of 2010 and claimed it would all be repealed.

Fifteen states have begun Medicaid EHR Incentive Programs since January 2011 and CMS has announced that Eligible Professionals and Hospitals have received over $83 million through the Medicaid incentive program alone as of April 30th. The Medicare program on May 19th, released $75 million in incentives and CMS has begun posting the names of EPs and EHs that have received incentives through the Medicare program and will keep the list updated. The Stage 1 attestation process and the potential for subsequent CMS audits is an issue that must be addressed. Whether I am speaking with vendors, eligible professionals, HIT journalists or other stakeholders the question slips out, usually at the last minute. “So the EP could actually just make up numbers during the attestation process?” The question is usually followed by a nervous laugh. Yes, it is true that the attestation process for Stage 1 MU EHR incentives is primarily based on EPs telling the truth. The input fields can be viewed on the CMS Attestation User Guide for EPs. One can see the fields for inputting the various denominators, denominators, and exclusions. The numbers will be coming from either your certified EHR technology or your practice’s workflow documentation.

Some EPs might be tempted to enter attestation numbers and measure statements that are not supported by adequate documentation. Let me tell you three reasons to resist that option:

1. It is wrong;
2. It is fraud;
3. You might get caught and get in big trouble.

CMS has announced that there will be audits: “There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment. Post-payment audits will also be completed during the course of the EHR Incentive Programs.” The audit process is in development and details have not been released, however it could be extremely rigorous. If CMS should allow contractors to perform audits they could be compensated based on a percentage of unsupported incentive payments that were received. The RAC audits of hospitals are a good example of what contractors motivated by compensation could do to turn over every stone in examination of documentation. If an audit reveals an EP (or EH) is not eligible for received incentives, CMS will want the incentive returned. So here is my advice: tell the truth supported by relevant documentation that is saved for at least 6 years. This documentation should also include the underlying data for your reported clinical quality measures. I guarantee you will sleep better. Especially when you starting hearing about EPs and EHs who are being audited in a year or two.

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