An eligible professional (EP), eligible hospital, or critical access hospital (CAH) attesting to receive an incentive
payment for either the Medicare or Medicaid Electronic Health Record (EHR) Incentive Program may be subject
to an audit.
The Centers for Medicare & Medicaid Services (CMS), and its contractor, Figliozzi and Company, will perform
audits on Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the EHR
Incentive Programs. States, and their contractor, will perform audits on Medicaid providers participating in the
Medicaid EHR Incentive Program.
Pre- and Post-Payment Audits
In addition to the pre-payment edit checks that have been built into the EHR Incentive Programs’ systems to
detect inaccuracies in eligibility, reporting, and payment, CMS will begin pre-payment audits in 2013, starting
with attestations submitted during and after January 2013. These pre-payment audits will be random and may
target suspicious or anomalous data. Providers selected for pre-payment audits will have to present supporting
documentation to validate submitted attestation data before CMS will release payment.
CMS through its contractor will also conduct post-payment audits during the course of the EHR Incentive
Programs. Providers selected for post-payment audits will also be required to submit supporting documentation
to validate their submitted attestation data.
EPs, eligible hospitals, and CAHs should retain all relevant supporting documentation—in either paper or
electronic format—used to complete the Attestation Module as follows:
Documentation to support attestation data for meaningful use objectives and clinical quality measures
should be retained for six years post-attestation
Documentation to support payment calculations (such as cost report data) should follow the current
documentation retention processes
Medicaid providers can contact their State Medicaid Agency for more information about audits for Medicaid
EHR Incentive Program payments.
Below is an overview of the audit process:
Initial request letters will be sent to providers selected for an audit he request letter will be sent electronically by Figliozzi and Company from a CMS email
address to the email address provided during registration for the EHR Incentive Program
The letter will include contact information for Figliozzi and Company
The initial review process will be conducted using information provided in response to the request
Additional information may be needed during or after the initial review process
In some cases an on-site review at the provider’s location may follow
A demonstration of the EHR system may be required during the on-site review
Figliozzi and Company will use a secure communication process to assist the provider in sending
Any questions pertaining to the information request should be directed to Figliozzi and Company.
If the provider is found to be ineligible for an EHR incentive payment, the payment will be recouped.
CMS has an appeals process for EPs, eligible hospitals, and CAHs that participate in the Medicare EHR Incentive
Program. Providers may contact the EHR Information Center through a toll free number, 888-734-6433,
between 9 a.m. and 5 p.m. EST, Monday through Friday, for general questions on how to file appeals and the