Meaningful Use Bonus Recipients Audited

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  • September 12, 2012
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Figliozzi and Co., an accounting firm based in Garden City, N.Y., has started post-payment audits for hospitals and eligible professionals who have claimed successful meaningful use of electronic health records (EHRs). The process starts with a mailed letter sent from the Centers for Medicare & Medicaid Services (CMS) to physicians who have received an incentive check, saying he or she is being audited. Practices are required to reply within two weeks upon receiving the letter.
The auditing process is a 2009 federal stimulus package Congressional requirement for professionals authorized to receive EHR bonuses. In 2011 and 2012, more than 55,000 physicians demonstrated meaningful use and received incentives.
If during the post-payment audit a physician or hospital is found ineligible for EHR meaningful use incentives, the bonus payment must be returned. As long as the practice has supporting documentation and reports attesting to meaningful use, they won’t have to send back the money.
The audit letters ask physicians to provide these three things:

  1. Proof that the EHR system is certified to meet meaningful use requirements. See the Office of the National Coordinator for Health Information Technology’s (ONC) website for a list of certified EHRs.
  2. Supporting documentation proving that 15 core objectives were met to achieve Stage 1 meaningful use. EHR systems that are certified to meet meaningful use can generate electronic or paper reports showing the objectives were met.
  3. Documentation supporting that meaningful use of five of the 10 menu objectives in Stage 1 were met. EHR-generated reports supporting clinical quality measures can show these objectives were met.

Hospitals need documentation supporting emergency department admissions reporting methods in addition to the above.
No one can tell for sure which eligible professionals or hospitals will be chosen for a meaningful use post-payment audit. Selection may be based on specific information or risk factors, but some audits are random, according to CMS spokesman Joseph Kuchler.
Source:, “CMS Starts Auditing Recipients of Meaningful Use Bonuses

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  1. scott rusco says:

    Do we have to pay federal and state income tax on our EHR bonus payment?