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This week some providers participating in the Medicare Electronic Health Record (EHR) Incentive Program began receiving emails notifying them that they have been selected for an EHR Pre-Payment Audit.
According to CMS, these prepayment audits, which still start with attestations submitted during January 2013, are random, but may target suspicious or anomalous data. The audits will be conducted by CMS and its contractor, Figliozzi and Company.
Normally Medicare EHR incentive payments are made to providers approximately 8 to 12 weeks after eligible providers successfully attest to meaningful use of EHR. Providers selected for prepayment audits, however, will have to present supporting documentation to validate submitted attestation data before CMS will release incentive payments. Audits should not disrupt regular Medicare claims payments.
Prepayment audits were recommended in a Department of Health and Human Services Office of Inspector General report published in November 2012.
CMS also anticipates conducting post-payment audits during the course of the EHR Incentive Programs. Additionally, states and their contractors will perform audits on Medicaid providers participating in the Medicaid EHR Incentive Program.
Catherine A. Brandon, JD, can be reached at Arnold & Porter LLP, 555 12th St. NW, Washington, DC 20004-1206; 202-942-6823; email: email@example.com