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Audits for the Medicare and Medicaid EHR Incentive Programs Audits for the Medicare and Medicaid EHR Incentive Programs

Audits for the Medicare and Medicaid EHR Incentive Programs - PowerPoint Presentation

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Uploaded On 2016-09-10

Audits for the Medicare and Medicaid EHR Incentive Programs - PPT Presentation

Vidya Sellappan HIT Initiatives Group CMS 1 Audit Basics Any provider that receives an EHR incentive payment for either EHR Incentive Program may be subject to an audit CMS and its contractor Figliozzi and Company will perform audits on Medicare and duallyeligible Medicare and Medicai ID: 463654

cms documentation audits ehr documentation cms ehr audits audit incentive providers medicaid provider medicare guidance payment programs attestation subject

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Slide1

Audits for the Medicare and Medicaid EHR Incentive Programs

Vidya SellappanHIT Initiatives Group, CMS

1Slide2

Audit Basics

Any provider that receives an EHR incentive payment for either EHR Incentive Program may be subject to an

audit.

CMS, and its contractor, Figliozzi and Company, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the EHR Incentive

Programs.States, and their contractor, will perform audits on Medicaid providers participating in the Medicaid EHR Incentive Program.

2Slide3

Medicare Audits

Medicare EPs and Dual-Eligible Hospitals

Pre- and post-payment audits are performed

5-10% of providers subject to pre/post-payment audits

Random audits and risk profile of suspicious/anomalous data

If a provider continues to exhibit suspicious/anomalous data, could be subject to successive audits

In order to ensure robust oversight, CMS will not be making the risk profile public

3Slide4

Medicare Documentation

It is the provider’s responsibility to maintain documentation.

Documentation

to support attestation data for meaningful use objectives and clinical quality measures should be retained for

six years

post-attestation.

Save any electronic or paper documentation that supports attestation, including documentation that supports values

the provider

entered in the Attestation Module for

CQMs.

Hospitals should also maintain documentation that supports their payment calculations. Medicaid providers can contact their State Medicaid Agency for more information about audits for Medicaid EHR Incentive Program payments.

4Slide5

Primary Source Documentation

5

Primary source document is usually the report generated by the provider’s certified EHR technology

Report should contain the following elements:

Numerators and denominators for the measuresTime period the report covers Evidence to support that it was generated for that provider (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.

)

Snapshot vs. rolling reportsSlide6

Audits and the 2014 CEHRT Flex Rule

CMS released a final rule in September allowing CEHRT

flexibility

for an

EHR Reporting Period in 2014.CMS will continue to follow standard guidelines used for CMS programs with audit provisions, including: Auditing providers based on a random selection processSelection also based on key identifiers such as prior audit failure or known incidence of fraud Providers will not be targeted by provider type, location, stage of meaningful use, or participation year.

CMS will provide guidance to auditors relating to the

final rule.

Auditors will be instructed to work closely with providers on the supporting documentation

needed.

6Slide7

Documentation Guidance: Stage 1

7

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR_SupportingDocumentation_Audits.pdf

Slide8

Documentation Guidance: Stage 2

8

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_AuditGuidance.pdf

Slide9

Audit Resources

Audit resources found on CMS EHR Incentive Programs Educational Resources webpage:

Supporting Documentation for Audits

Sample Audit Letter for EPs

Sample Audit Letter for Eligible Hospitals & CAHsAudit Overview Fact Sheet

9