A New Kind of Meaningful Use Audit

Written on April 28, 2015

By: Tammie Lunceford, CPC

The Centers for Medicare and Medicaid have conducted audits the past two years by contracting with Figliozzi & Company. The contractor focused on all measures for a specific attested year. The Office of Inspector General (OIG) has criticized the Department of Health and Human Services for not providing proper oversight of the Meaningful Use program.

The Office of Inspector General is following the 2014 OIG Work Plan by focusing on a number of areas related to electronic medical records. The OIG is not particularly looking at individual providers but they are focusing on state Medicaid Meaningful Use programs and hospitals, which could lead to individual providers. The OIG is looking at specific measures over a three year period.

OIG Focus Areas

  • Were the providers who received Medicare or Medicaid money entitled to the money?
  •  How well is CMS overseeing the money being paid?
  •  CMS oversight of hospital security controls over networked medical devices and HER.
  •  The security of patient records between covered entities and business associates.  Did the hospital or provider conduct a security risk analysis?
  •  Does the hospital have EHR contingency plans as required by the HIPAA security rule?

Who will contact you?
The Office of Inspector General is conducting these audits—not a contractor.

What will they request from you?
They will request the information you gave to the state and:

  • Costs Reports
  • Patient Records
  • Security Plan

What are the penalties?
If the OIG finds the state issued incentive money inappropriately, they will send a report ordering them to recoup the payment.

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