Meaningful Use Audits: Be Prepared

TMA is hearing from physicians who are being audited for meaningful use and some who have had their meaningful use incentive dollars recouped. Don't let this happen to you. Remember: Meaningful use is all or nothing. Physicians must meet all measures for successful attestation. This includes conducting a security risk analysis for HIPAA to ensure protection of patient information.

The Centers for Medicare & Medicaid Services (CMS) has indicated about 6 percent of those receiving incentive payments will be audited. If a physician fails an audit and continues to participate, the audits continue before CMS makes another payment. Anyone who receives the incentives could be audited, and recipients should retain all supporting documentation for six years.

TMA has these recommendations to help practices:  

  • Take screen shots of electronic health record (EHR) reports indicating you met a meaningful use measure. If you try to re-create a report at a later date, the EHR may return a different result. 

  • When the meaningful use criteria specify "more than," that doesn't mean "equal to." For example, if the criteria indicate you need to record demographics for more than 80 percent of your patients, then your denominator and numerator should be such that they don't total 80 percent. They must be more. 

  • Keep a meaningful use file (paper or electronic) with all documentation, and know where that file is. Staff turnover could mean the person who created the file is no longer working for you when the audit request comes.  

The Garden City, N.Y., accounting firm Figliozzi & Co. is conducting the audits for CMS. The firm is sending letters asking for documentation supporting the meaningful use attestation. Figliozzi seeks these types of data: 

  • Documentation showing use of a certified EHR system for meaningful use attestation; 

  • Documentation showing completion of the attestation for the core set of meaningful use criteria; and

  • Documentation showing completion of the required number of menu set meaningful use objectives. 

Physicians and others selected for the audits have two weeks to submit their documentation. The audits don't involve site visits. If physicians are ineligible for payment, they may file an appeal through CMS. 

For questions about audits, the incentive program, and other health information technology matters, contact TMA's Department of Health Information Technology at (800) 880-5720 or by email

Action, Dec. 1, 2014

Last Updated On

December 02, 2015

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