Questions Around EHR Incentive Payment Audits

Questions Around EHR Incentive Payment Audits

EHR Incentive Audits for Medicaid EPs

CMS lays it out there as concisely as possible: “Any provider attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program potentially can be subject to an audit”.  Over the past few months I have received a growing number of calls and emails from eligible professionals (EPs) and health information technology vendors with questions about audits. Some of these calls are from EPs who are experiencing an audit while others are from vendors who want to turn in EPs that they believe are fraudulently using their certification number. That’s right. I have been contacted by vendors who want to know if there is a “whistle blower” phone number where they can reports EPs. They believe they have evidence that specific EPs have simply lifted the number, required for attestation, from the Certified Health IT Product List.

CMS has awarded a contract to a single firm that has begun performing meaningful use audits for eligible professionals (EPs) who have received EHR incentives under the Medicare program. The use of centralized auditing protocols for all Medicare incentive audits sounds like a Best Practice to me. I like clarity and consistency. But what about those pesky Medicaid EP audits? As of November 2012 69,395 Medicaid EPs have received a total of $1,411,873,814 in incentives. That’s a lot of clicking and scrolling. Whose is doing the Medicaid EP audits? Where are those Medicaid audits? They must be out there somewhere but I have yet to hear of one. Unlike the Medicare incentives, there is no central body responsible for audits.  Auditing oversight is left up to each and every state. “CMS, and its contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers. States, and their contractors, will perform audits on Medicaid providers.”

The Medicaid EHR incentive program for EPs has higher incentives, extremely minimal requirements for the initial year, no penalties, and an extended timeline for HIT adoption. Looks like a less consistent audit program may be the icing on the cake. Since 90% of the money for Medicaid incentives is coming from the Federal Government, I’m hoping there is someone at the Federal level keeping an eye on this and making sure robust oversight is taking place at the state level. I have tried without success to unearth much information on the Medicaid EP audits. If anyone has any information, please pass it along to me at

Jim Tate is founder of EMR Advocate and a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use.