Brief description of audits process to covered entities that have implemented EHRs and apply for meaningful use.

2. BASICS
Any Covered Entity who receive an
EHR incentive payment may be
subject to an audit.
Documentation to support attestation
data for meaningful use objectives
and clinical quality measures should
be retained for six years post-
attestation.

3. PRE-PAYMENT AUDITS
Beginning January 2013 Providers may
be audited before receiving
incentive money.
Systems designed with pre-payment
edit checks built to detect
inaccuracies.
5% to 10 % of new Providers to be
selected.
 Random selection
 Providers submitting suspicious or
anomalous data

4. AUDITORS
Centers for Medicare & Medicaid Services (CMS) - Figliozzi and Company
Medicaid - States and their designated contractors

5. CMS (MEDICARE) AUDIT PROCESS
• Letter from Figliozzi and Company with request for information
• The initial review process will be conducted at the audit contractor’s
location
• Additional information might be needed during or after this initial review
process
• Potentially an onsite review at the provider’s location could follow.
• A demonstration of the certified EHR system could be requested during
the on-site review.

6. PREPARATION PRIOR TO AUDIT
System Functionality
Recommended Documentation
Common Questions

7. SYSTEM FUNCTIONALITY
Drug-Drug/Drug-Allergy Interaction Checks
and Clinical Decision Support
oAvailable, Enabled and Active
Clinical quality measure data
oReported directly from certified EHR system

8. SYSTEM FUNCTIONALITY (CONTINUATION)
Electronic Exchange of Clinical Information
oTest of certified EHR technology’s capacity to
electronically exchange key clinical information
Drug Formulary Checks
o Available, Enabled and Active

9. RECOMMENDED DOCUMENTS
Any electronic or paper documentation that
supports attestation.
Documentation that supports the values entered
in the Attestation Module for clinical quality
measures.
Report from the certified EHR system to validate
all clinical quality measure data entered during
attestation

10. RECOMMENDED DOCUMENTS
Note: Because some certified EHR systems are unable to
generate reports that limit the calculation of measures to
a prior time period, CMS suggests that providers
download and/or print a copy of the report used at the
time of attestation for their records.

11. FAILURE CONSEQUENCES
Return Incentive Money
Fraud Charges
Lose of Medicare privileges

12. RECOMMENDATIONS
 Conduct mock audits
 Ensure Policies reflect Meaningful Use Requirements
 Train Staff
 Document, Document, Document