Audit 3d Word Sphere with magnifying glass on white background.Meaningful Use audits are currently conducted by Figliozzi & Company. Pre-payment audits occur shortly after attestation and post-payment audits occur up to 6 years after an attestation. These audits are performed against a single attestation.

However, a new wave of MU audits have been  launched by the Office of the Inspector General (OIG).

According to OIG, “We will review Medicare incentive payments to eligible health care professionals and hospitals for adopting EHRs and the Centers for Medicare & Medicaid Services (CMS) safeguards to prevent erroneous incentive payments. We will review Medicare incentive payment data from 2011 to identify payments to providers that should not have received incentive payments (e.g., those not meeting elected meaningful use criteria). We will also assess CMS’s plans to oversee incentive payments for the duration of the program and corrective actions taken regarding erroneous incentive payments.

The OIG is therefore conducting oversight audits of providers to make sure that CMS is doing a good job handing out the EHR incentives. The OIG audits are similar to the Figliozzi & Company audits, yet there are also significant differences:

  • The OIG audit period covers all EHR incentive payments from January 1, 2011, through June 30, 2014.
  • When transmitting any audit information to OIG over the internet, providers must properly safeguard the information. OIG is required to report as a security breach any audit information sent to them that does not meet FIPS 140-2 requirements.
  • The OIG audit covers a period that could conceivably cover 4 attestations.

Providers are being asked to produce full documentation for multiple attestations. Depending on the provider’s ability to satisfy the request, up to 4 years of incentive payments could be recouped.

The stakes have gotten higher and more than ever you want to make sure your “Book of Evidence” is intact and validated.

Kentucky REC is here to help! We offer a full line of Meaningful Use services including Meaningful Use mock audits! Contact us at 859-323-3090 or email us at

Source: EMR Advocate