It’s 95 percent likely qualifying eligible hospitals (EH) that received payment from the Medi-CAL Electronic Health Record (EHR) Incentive Program were paid incorrectly and now are subject to significant recoupments.
The U.S. Department of Health & Human Services Office of Inspector General (OIG) recently completed audits of 64 California facilities with staggering results; 61 were paid incorrectly, creating a net overpayment in excess of $22 million. This set records for both the largest net overpayment and highest percentage of incorrect payments.
Based on its findings, the OIG recommended California review all remaining EHs that received an incentive payment from the Medi-Cal EHR Incentive Program. There will be payment adjustments if calculations are determined to be out of compliance during the review.
The inclusion of unpaid Medicaid days, nonacute care services and Medicaid dual-eligible, acute-care days were contributing factors in creating the California overpayments and also are culprits in many other states. The BKD EHR team has helped more than 100 providers navigate these OIG audits and look for adjustments to offset the negative recoupments.
Recommended Course of Action
Despite incorrect payments being net overpayments, there’s potential for positive adjustments. Keep in mind, finding positive adjustments for organizations isn’t the OIG’s priority. Many BKD clients have benefited from having their calculations reviewed. This allows an organization to proactively work to offset the net overpayment if dollars are at risk. BKD’s EHR team has helped clients recoup approximately $150 million and can help answer your questions.
California EHs should be diligent and proactive in addressing this recent OIG report. Contact your BKD advisor to discuss your EHR strategy or ask questions regarding:
- The OIG audit results and their effect on your EH
- Reviewing your EH’s payments to help avoid recoupment risk or determine any available positive adjustments
- Why your EH doesn’t qualify for the Medicaid EHR incentive payment program