This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program and related topics.
The HHS Office of Inspector General has announced plans to review the appropriateness of a walloping $14.6 billion of incentive payments made to providers over a five-year period. The upcoming report, which follows on a GAO study naming improperly issued incentive checks as the biggest threat to the Medicare EHR incentive program, addresses payments made between by CMS between January 2011 and December 2016.
The OIG’s current audit plans follow on research it previously conducted which estimated that the incentive program had wrongfully paid out $729 million incentive payments between just May 2011 and June 2014.
To conduct that review, the OIG sampled incentive payment records for 100 eligible providers, then used the level of erroneous payments found among them to extrapolate the total amount paid out wrongly by CMS during those three years.
This time around, the watchdog organization plans to audit all payments made during the entire past life of the incentive program, an exercise which could generate some even more dramatic numbers. If the prior research is any indication, the OIG could conclude that roughly 10 % to 12% of the entire $14.6 billion in incentive payments it issued shouldn’t have been made in the first place.
Of course, looked at one way this effort could be seen as closing the incentive door after the horses have left. Meaningful Use, by all accounts, is giving way to incentives under MACRA, which will apply distinctive criteria to its incentive payment formulas. Also, while I’m no numbers whiz, seems to me that you can’t really model the entire meaningful use program effectively using just 100 sample cases.
That being said, it does seem likely that the audit will find more situations in which physicians hadn’t submitted he right self-attestation data or couldn’t prove what they asserted, and if the federal auditor has any role to play, this research is probably a good idea
Sure, nobody wants to be audited, particularly when your healthcare organization has jumped through many hoops to comply with meaningful use rules. Even if you can afford to pay back your incentive money, why would you want to do so? And particularly if you’ve already played by the rules, you certainly wouldn’t want to prove it again. But since the audit is going to happen anyway, perhaps it’s best to get any possible pain it may generate out of the way.
To date, I haven’t read anything suggesting that CMS has immediate plans to claw back incentive payments from providers. My assumption, though, is that they will eventually do so. Governments need money to get their job done, and audits theoretically offer the added benefit of tightening up important initiatives like this one.
As someone who has worked exclusively in the civilian world, I have often made fun of the plodding pace at which federal and state government agencies operate. In this case, though, a slow, deliberate process — such as a gradually-widening payment review — is likely get the job done most effectively. Let’s establish carefully which incentive payments may have been issued inappropriately and clear the decks for MACRA.