GAO: CMS needs better EHR incentive program requirements

The first year of the Centers for Medicare & Medicaid Services’ (CMS) EHR incentive programs is currently lacking certain efficiencies to verify that providers meet the designated requirements, according to an April report from the Government Accountability Office (GAO).

The GAO examined efforts by CMS and states to verify whether providers qualify to receive EHR incentive payments and examined information reported to CMS by providers to demonstrate meaningful use in the first year of the Medicare EHR program.

For the Medicare EHR program, CMS has implemented prepayment processes to verify whether providers have met all of the eligibility requirements and one of the reporting requirements, the office found. “Beginning in 2012, the agency also has plans to implement a risk-based audit strategy to verify on a postpayment basis that a sample of providers met the remaining reporting requirements.”

For the Medicaid EHR program, the four states GAO reviewed implemented prepayment processes, postpayment processes or both. “CMS officials stated the agency intends to evaluate how effectively its Medicare EHR program audit strategy reduces the risk of improper EHR incentive payments, though the agency has not yet established corresponding timelines for doing this work.”

GAO stated that an evaluation could help CMS determine whether it should revise its verification processes and example of collecting certain data on states’ behalf could improve the efficiency of verification processes.

In order to improve the efficiency and effectiveness of processes to verify whether providers meet program requirements for the Medicare and Medicaid EHR programs, GAO recommended that the administrator of CMS take the following four actions:

• Establish time frames for expeditiously implementing an evaluation of the effectiveness of the agency’s audit strategy for the Medicare EHR program.
• Evaluate the extent to which the agency should conduct more verifications on a prepayment basis when determining whether providers meet Medicare EHR program’s reporting requirements.
• Collect the additional information from Medicare providers during attestation that CMS suggested states collect from Medicaid providers during attestation.
• Offer states the option of having CMS collect meaningful use attestations from Medicaid providers on their behalf.

CMS concurred with the first three recommendations and did not concur on the last, stating they believe there are no significant barriers to states implementing meaningful use attestation. “GAO continues to believe this action is an important step to yield potential cost savings,” the report concluded.