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Doctors, are you prepared for EHR incentive program post and pre-payment audits?

Security Risk Analysis Tipsheet

The goal for the “meaningful use” EHR Incentive Program is to promote adoption and implementation of certified electronic health records to improve quality, safety, efficiency, and reduce health disparities.

Providers must meet the MU criteria every year in order to receive incentives. To receive the incentive funds, providers must attest that they have met all the criteria. Anyone who receives an EHR incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program potentially may be subject to an audit.  The meaningful use audits have begun.

The accounting firm Figliozzi and Company was retained by CMS to conduct the audits. Effective now, there are a number of pre-checks that have been built into the attestation process to detect inaccuracies in eligibility, reporting, and payment.

Many providers have received emails notifying them of post-payment audits being conducted for incentive payments received for 2011 compliance. Now, for 2012 attestation compliance, many have received emails concerning pre-payment audits.  Providers must ensure adequate privacy and security protections for personal health information.  The CMS auditors have found our biggest weakness, the risk analysis and HIPAA Security policies and procedures requirement, CR15.

Meaningful use core requirement number 15 (CR15) has not been understood or completed by many providers that have attested “YES” to CR15 and that is exactly what the CMS auditors are asking for right out of the starting gate.  A copy of your Risk Analysis.  Since many have not completed CR15 for 2012, and it will be identified by the auditors in the pre-payment audit, it will give the auditors the “reason” to go back and conduct a post-payment audit of 2011.

The initial review will be conducted at the auditor’s location using the information received from the provider. In some cases, an onsite review at the provider’s location may follow.

Once the audit is complete, the provider will be notified if they were determined to meet the MU criteria. If the provider is found ineligible, or failed to meet even one measure, the payment will be recouped.

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