CMS Now Auditing Meaningful Use Documentation

It’s been a while since our beloved Recovery Audit Contractors (RAC) were on the front page of the trades every day, but they’re far from gone.  In fact, CMS has started to get aggressive in a few new ways, according to the Fox Group:

  • Meaningful Use Attestation Audits:  So you’ve collected EMR data, you’ve attested, and you’re waiting for your check. All is well, right?  Not necessarily. CMS has begun requesting documentation from providers that supports  the attestation, largely data from your EMR but also possibly info from internal audits you’ve conducted to see that you’re meeting objectives.  This is big stuff; if you fail your audit by CMS, there goes your money. And in the future, if you fail multiple audits, you could be seen as submitting false claims. Mega-ouch.
  •  MACs Look At Documentation:  Medicare Administrative Contractors (MACs) have been auditing medical records for years to make sure documentation supports the services billed. Now, they’re going to start looking at “auto-generated data” produced by EMR medical record documentation systems.  If the auto-documentation looks “cookie-cutter” and possibly out of line for some specific patients, providers could be in trouble.

And if you somehow get entangled with a RAC investigation, don’t count on carefully-spelled-out EMR documentation to save you. According to a recent study by the American Hospital Association, 77 percent of claims denied by RACs were restored upon appeal, suggesting that most of the time, claims targeted by the RACs weren’t bad to begin with. In other words, I think it’s fair to say that they’re out for blood, so prepare yourself.

An internal audit of your documentation can work wonders, Fox Group suggests. And keep an eye out for copy-and-paste documentation across bunches of patients; it’s gone from questionable to perilous.

About the author

Anne Zieger

Anne Zieger

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.


  • While these audits are proof of CMS’ efforts to make sure meaningful use attestation is accurate and properly managed, the news comes as a potential headache to some. The view of these audits from the perspective of small practices is quite different than their larger counterparts, yet it is hardly discussed. Small practices in particular rely on government incentive money to make up for some of the cost associated with implementing new HIT initiatives such as EHR adoption. Even a minor mistake could lead to a failed audit and denial of incentive cash, which would be a crushing blow to small practices.

    EHR vendors that specifically target small practices have also voiced their concern about these audits. In a recent blog post, VitalHealth states that “I am sure we are not alone in hoping that audits of this kind do not expanded to include small practices. Between meaningful use attestation,HIEs, ACOs, ICD-10, breach prevention and 19 other regulatory-driven IT initiatives, and the growing list of quality, patient sat, coding and billing audits and required reports, practices have way more IT initiatives and reporting requirements on their collective plates right now.”

    Read more here:

  • Has any one heard of a particular EHR provider’s reports not being sufficient for the audits? We have heard a rumor and just want to know if anyone has had any problems.

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