Mock EHR Incentive Audits: Time to Get Serious – Part II

A Proactive Approach to Meaningful Use Audits– Part II

By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail:

I trust my post last week directed to Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) was convincing on the need to conduct mock audits on their CMS EHR Incentive attestations. There is simply too much at stake. I have seen enough failed audits and incentive recoupments to know there is some real risk out there. I imagine many of you have heard the same from your colleagues. A year ago a recoupment of funds was a rare occurrence, now it is all too common, and in many cases preventable. Here is what I promised to provide this week: Best Practices for Mock Audits of CMS EHR Incentives.

  • The mock audit should never be conducted by the same people that were involved in the incentive attestation. This should be obvious, as those individuals will have a tendency to have blind spots in terms of attestation strategy, acceptable documentation, and the “halo effect” of reviewing their own work.
  • The team performing the mock audit must be extremely knowledgeable in all aspects of the foundational elements of the CMS EHR Incentive programs. This includes certified technology, details of the relevant meaningful use (MU) requirements, and all updated CMS guidance and clarification.
  • The mock audit should follow as close as possible the documentation requests and process utilized by the CMS Medicare audit contractors, Figliozzi & Company.
  • If risks to the validity of an attestation are identified it is important that potential mitigation strategies are developed and put into place.
  • The findings of the mock audit and any mitigation plans and decisions should be fully documented.
  • If an expert team external to the organization performs the mock audit, the agreement should be between the hospital’s lawyer and the mock auditors.

The most critical aspect of a CMS EHR incentive mock audit is the personnel involved and their level of knowledge and experience. If that does not exist, the mock audit has no value. Wherever you find those resources, whether within or without of your organization, the value of a mock audit is beyond dispute. A stitch is time saves nine.

If you are interested in learning more about conducing a mock audit for your organization, please contact me at

Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at:  This post was originally published on