Hospital executives already lie awake at night worrying about Recovery Audit Contractor audits (RACs), whistleblowers, treble damage recoveries, and $5,500-per-false-invoice penalties.  Now they can add personal criminal indictment to the list—that is, if they plan to falsely certify “meaningful use” of electronic health records (EHRs) and to do so in some other hospital officer’s name.

The former CFO of a now-defunct Texas hospital has been criminally indicted by the feds for falsely certifying that his hospital was entitled to $785,000 under the 2009 stimulus package because it met the EHR meaningful use standard.

It turned out that (a) the hospital had not met the standard and (b) the CFO falsely signed the name of the administrator in charge of attestation.  Why did the CFO impersonate the administrator?  Because the administrator wouldn’t sign the false certification.

One practical take-away for hospitals (beyond the obvious ones:  don’t make false certifications and don’t pretend to be someone you’re not) is that EHR meaningful use is yet another area that should be added to the hospital’s compliance program and annual internal audit plan.