Health Care Payment Reform Center

Electronic Health Record (EHR) Incentive Payment Programs

Numerous governmental organizations and politicians have grumbled over the lack of oversight for electronic health record (EHR) incentive payment programs. In light of these issues and others—including the impending end of scheduled EHR program funding—audit processes are continuing.

An eligible hospital (EH) can have several different EHR audits going on at once—Medicare HITECH, Medicaid prepayment, Medicaid AIU, Medicaid post-payment, Meaningful Use (MU), Federal OIG audits and others. Any of these can be a huge task and have significant negative effects on incentive payments.

BKD’s EHR team can help EHs through these audits. We understand the aggravation and time lost to each of these audits, and we’ve developed services to help you find additional dollars and—more importantly—keep them. Our EHR consulting services help with these potentially overwhelming audit processes.

Meaningful Use Audit Assistance

EHs that fail an MU audit will be required to pay back any Medicare and/or Medicaid incentive payments received for that program year within 30 days. Failing an MU audit also triggers an automatic MU audit for the subsequent year and all preceding MU attestations before the failed program year.

We’ve helped more than 75 EHs through actual MU audits. That experience has helped EHs keep their valuable incentive payments and avoid future audits. BKD has been extremely successful in helping hospitals develop mitigating strategies and solutions to pass an MU audit. We help EHs in every stage, including:

  • Gathering and reviewing requested MU audit documentation
  • Packaging supporting documentation into the preferred format for MU auditors
  • Helping with mitigating strategies for answering MU auditor questions after the supporting documentation has been submitted
  • Assisting with the Centers for Medicare & Medicaid Services (CMS) appeals process for an EH that already has received notification of failure

Meaningful Use Documentation Analysis (MUDA)

EHs receiving negative determinations will owe the CMS the entire EHR incentive payment for Medicare and/or Medicaid for the program year under audit. Fortunately, failing this type of audit due to lack of appropriate documentation can be avoided.

One of the main reasons EHs fail MU audits is the different schools of thought between the information technologists gathering the data and auditors or CPAs requesting and reviewing the data. Through our experience helping EHs, we’ve gained a solid understanding of the supporting documentation MU auditors typically accept. In addition, we can help uncover and correct potential issues before they lead to recoupments. This service also offers peace of mind to EHs not currently under MU audit.

Medicare & Medicaid Attestation Assistance

BKD can guide EHs that have not yet attested to the Medicare or Medicaid EHR incentive programs through the entire process with step-by-step instructions and live online technical support. Our team can assist with the subsequent-year attestations throughout both EHR program processes. That way, your EH will know exactly which MU stage it should attest to, when it can attest, what important dates are approaching or what penalties may await.

Medicare & Medicaid EHR HITECH Payment Audits

These audits review each variable in the EHR formulas as well as the supporting documentation for those variables. Based on their findings, auditors can make adjustments that lead to EHR recoupments.

Our team will look for positive adjustments through this audit process that can help offset negative adjustments made during the HITECH audit. We even look outside the scope of the cost report at EHR variables to search for additional incentive dollars.

Two key areas heavily reviewed by auditors are charity care and Medicare/Medicaid days. BKD assists EHs with both of these, in addition to other areas often overlooked during these audits. We also can help EHs before or during an EHR HITECH incentive payment audit from Medicare, Medicaid or the OIG.

  • Medicare HITECH payment audits are conducted by the EH’s Medicare Administrative Contractor; every EH will have each EHR settlement audited at some level.
  • Medicaid HITECH payment audits are conducted by outside vendors that contract with individual states and are subject to audits based on each state’s CMS-approved HITECH plan.
  • The OIG has said EHR is a high priority on its work plan for coming years and has the freedom to audit both Medicare and Medicaid—and even the MU side in 2018.

Medicare & Medicaid Settlement Review & Day Analysis

BKD has extensive experience assessing Medicare and Medicaid incentive payments to evaluate whether facilities have received appropriate EHR incentive payments or if there are any potential unforeseen risks that could be detrimental to the facility. This assessment offers deeper analysis of what goes into the EHR calculations and a more detailed view of variables used in the EHR calculation for incentive payment programs. BKD has helped more than 300 EHs nationwide recover $175 million in additional incentive payments.

Great Plains Health Alliance (GPHA)

"BKD has an excellent understanding of our organization, so its advisors are able to bring solutions of which GPHA may not have been aware. Case in point: BKD assisted our hospitals in enrolling in the Medicaid EHR program. The BKD team identified the incentive program, informed and communicated with our hospitals, used cost report data to yield greater savings and completed the project in a timely manner."

— Dave Dellasega, CEO
Great Plains Health Alliance (GPHA)
Wichita, Kansas

Family Health Centers

"BKD recently provided additional consulting services when we were selected by the Office of Inspector General (OIG) for a random audit of our stimulus funds. BKD provided practical advice which helped us effectively prepare, relate and interact with OIG.”

— Bill Wagner, CEO
Family Health Centers
Louisville, Kentucky

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