In an effort to improve patient care, the Centers for Medicare and Medicaid Services (“CMS”) established electronic health record (“EHR”) Incentive Programs, which provide financial incentives for the “meaningful use” of certified EHR technology. To receive the incentive payment through the EHR Incentive Program, providers must show that they are “meaningfully using” their EHRs by meeting a number of objectives. CMS has established a list of objectives to determine “meaningful use.” Now, providers who participate in the EHR Incentive Programs may be audited to determine their compliance with these established objectives.

CMS has announced it will begin Meaningful Use audits of the EHR practices and records of healthcare providers utilizing the EHR Incentive Programs. CMS’s Meaningful Use audits will help determine if improper billing practices are being utilized, as well as whether providers utilizing EHR deserve a Meaningful Use incentive payment. As CMS begins to conduct EHR Meaningful Use audits, healthcare providers participating in CMS’s EHR Meaningful Use Incentive Programs should review current practices and procedures to guarantee compliance.

Providers evaluating EHR practices and records to ensure compliance with the Incentive Program requirements should review the following:

  1. Create a staff training program that incorporates proper EHR practices and billing and coding requirements.
  2. Monitor EHRs to ensure that proper coding occurs and that billing is not erroneously affected by EHR functions like auto fill, which can result in improper coding.
  3. Maintain a file that documents compliance with the meaningful use requirements, in anticipation of future audits.
  4. Ensure full compliance with each and every attestation requirement before checking the box on the CMS form indicating meaningful use.
  5. Best Practice: Don’t forget HIPAA Compliance. Update your new system to comply with the HIPAA Security Rule. 

For more information regarding CMS’s EHR Meaningful Use Incentive Programs, visit: