When I read recently about the new pre-payment audit plan to assess accuracy of the Medicare Electronic Health Record (EHR) Incentive Program payments, I was not surprised at all. In fact, I expected these audits would have been conducted sooner. CMS has indicated for years that they are stopping pay and chase (paying claims and then chasing to recoup errors) and will attempt to eliminate inappropriate payments from being made in the first place. That method of stopping the pay and chase has been introduced into the Medicare EHR Incentive Program starting with the attestations made in January 2013. Providers are now subject to pre-payment audits, yet not all providers receiving a letter from the contractor, Figliozzi and Company, for a pre-payment audit will be under suspicion. Some providers will be randomly selected in addition to those that have been targeted.
The initial request letters will arrive from a CMS email address and are sent to the email address providers indicated during their registration process. It appears that providers need a coordinated effort to ensure that such letters are routed within their organizations to the correct parties handling audit requests.
To learn more about the documentation that CMS expects to be maintained, read the CMS Notice. If your organization has yet to develop a systematic process to collect and store its supporting documentation, now is the time to start. Then ensure that your record retention schedule includes these documents to be retained for the required six years. Also, make sure to include the Compliance or Internal Audit personnel in your process for attesting to meaningful use.
Although having the payment denied or recouped in the event of a post-payment review may seem harmful to providers, being viewed as defrauding the Federal Government could have more significant punishments attached.
What’s the moral of the story? Maintain great documentation, have internal audits of attestations to detect any errors, and be prepared to submit to an audit at any time as the turnaround times to provide your supporting documentation may be short.
Camille Cohen is the Compliance Officer with 3M Health Information Systems.