The Office of Inspector General (OIG) has been reviewing the Medicaid electronic medical records (EMR) incentive payments for both eligible professionals (EP) and eligible hospitals (EH) for the past year and a half. It’s been reviewing a small sample of the largest payments issued to EHs—and an even smaller sample of payments issued to EPs—per state.
OIG found a lot of overpayments for EHs and EPs—roughly $66.7 million in overpayments for the Medicaid portion for EHs (even before reviewing $14.6 billion in Medicare payments) and an extrapolated $729 million in overpayments to EPs.
Worried about large potential overpayments of taxpayer dollars, Congress has started pressuring the Centers for Medicare & Medicaid Services and OIG to begin auditing and collecting. Once the push to collect was publicized, there was severe pushback from the major EP players.
Per recent reports, OIG made a midyear update to its 2017 work plan to conduct another round of EMR audits.
This update specifically targets Medicare payments made to EHs. OIG is targeting payments made during program years 2011 to 2016, which totaled roughly $14.6 billion.
Act now before OIG comes calling to audit your facility. If OIG audited a facility today for payments received in 2011, most facilities would have problems providing the data for many reasons.
Here are some of the biggest problems BKD has seen when assisting hospitals trying to provide data for any EMR audit (Meaningful Use, Medicare or Medicaid):
- Management has changed
- Information technology leaders that were in charge of EMR are gone
- Facility changed EMR systems (maybe more than once) and left the previous system on unfriendly terms
- The data has been purged from their system
- Facility didn’t keep detailed records for all EMR payment variables
If any of these issues sound familiar, immediately address them so there’s time to gather the data. There’s no reason to struggle through an EMR audit. Having your data gathered and reviewed well before OIG calls can provide peace of mind.
The auditor will seldom have any positive adjustments suggested for the auditee during a governmental audit. However, numerous positive adjustments can be made that most likely would negate some negative adjustments or increase the payment for that particular payment year.
If you’d like to discuss these audits, the data needed or potential positive adjustments in more detail, contact a member of the BKD EMR health care team.