CMS contractor begins meaningful use audits

The Centers for Medicare and Medicaid services (CMS) announced that a third party contractor, Figliozzi and Company, will be conducting meaningful use audits for CMS. Providers who are selected for an audit will receive a letter from Figliozzi and Company with the CMS logo on the letterhead advising them that they have been selected for an audit. Meaningful use audit questions can be directed to Petere Figliozzi at (516) 745-6400 x302 or by email at pfigliozzi@figliozzi.com. Figliozzi and Company’s website is http://www.figliozzi.com/.

Figliozzi and Company will be performing audits to:

Eligible Professionals

• Medicare
• Medicare Advantage (MA)

Eligible Hospitals

• Medicare only
• Dual Eligible (including MA hospitals)
  CMS has provided the following information related to audits for providers attesting to receive an EHR incentive payment for the Medicare or Medicaid EHR Incentive Programs:

  Overview of the CMS EHR Incentive Programs Audits

  • All providers attesting to receive an EHR incentive payment for either Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format used in the completion of the Attestation Module responses).  Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.
  • 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.
  • CMS and states will also manage appeals processes.

  Preparing for an Audit

  • To ensure you are prepared for a potential audit, save the supporting electronic or paper documentation that support your attestation. Also save the documentation to support your Clinical Quality Measures (CQMs). Hospitals should also maintain documentation to support their payment calculations.
  • Upon audit, the documentation will be used to validate that the provider accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.

  Details of the Audits

  • There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment.
  • Post-payment audits will also be completed during the course of the EHR Incentive Programs.
  • If, based on an audit, a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped.
  • CMS will be implementing an appeals process for eligible professionals, eligible hospitals and critical access hospitals that participate in the Medicare EHR Incentive Program. More information about this process will be posted to the CMS Web site soon.
  • States will implement appeals processes for the Medicaid EHR Incentive Program. For more information about these appeals, please contact your State Medicaid Agency

Please visit www.cms.gov for more information.

Information in this article was provided by the Centers for Medicare and Medicaid Services: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/