Mock EHR Incentive Audits: Time to Get Serious

A Proactive Approach to Meaningful Use Audits – Part I

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

Well, you could wait and play the odds and hope you are one of the hospitals that doesn’t get audited for those CMS EHR Incentive attestations that brought in seven figure incentives. This is what most Eligible Hospitals (EHs) and Critical Access Hospitals (s) are doing. You could ignore the nagging doubt about the 2011 documentation gathering dust on the shelf. What about the staff that did the attestation all those years ago? They might be long gone by now and you could hope they did the right thing and their actions will not come back to wreak havoc on your reputation and career. Who wants to be left holding the bag? Might be best to not look under the rock, no telling what you might find. Time to review the pros and cons. Should hospitals perform mock audits on their CMS EHR Incentive attestations?

Reasons to not do an audit:

  • You might find out something bad and then have to decide what to do.

Reasons to do an audit:

  • You can relieve yourself of the nagging doubt of whether your hospital might get audited and whether it would pass.
  • If problems are identified you may be able to employ a mitigation plan. This might allow you to correct an erroneous attestation. Once a real audit begins, it is too late for that action.
  • If a mock audit finds problems, even if the deadline for correction has passed, subsequent attestations will benefit by not repeating the same problem and risking the recoupment of future incentives.
  • Those that follow you in the years ahead will bless you for leaving clear documentation on meaningful use strategy, related decisions, and clear vendor and regulatory documentation.

I think it is obvious what I think of mock audits. I believe in the proactive approach. 2011 and 2012 attestations were done in the face of limited guidance and clarification. Even today the knowledge gaps are widespread. Better to do the right thing, take care of this, and move on to something important like trying to improve patient care. Just go ahead and turn over those rocks and take care of anything that slithers out.

Next week I’ll discuss best practices for mock audits and lay out a few suggestions to care of this threat once and for all.

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 original published on