OIG: Lack of data stymies Medicaid EHR incentive verification

Data availability limits the number of eligibility requirements that state Medicaid agencies plan to verify prior to payment of Medicaid EHR incentives, according to a report from the Department of Health and Human Services' Office of the Inspector General (OIG).

The July 15 report, titled “Early Review of States' Planned Medicaid Electronic Health Record Incentive Program Oversight,” reviewed 13 states’ Medicaid EHR incentive payment verification plans.

Under the provisions of the HITECH Act, state Medicaid agencies administer their own Medicaid EHR incentive programs. These agencies must have an oversight plan that includes verifying that healthcare practitioners and hospitals meet program eligibility requirements. Oversight plans may include verifying self-reported information for eligibility requirements prior to payment or auditing self-reported information after payment.

The OIG reviewed 13 of the 14 states that had approved Medicaid EHR incentive program plans as of Jan. 14. The office reviewed these states’ 2011 prepayment and post-payment oversight plans for their EHR incentive programs, focusing on their plans for ensuring that practitioners and hospitals met EHR incentive program eligibility requirements, according to the report.

All of the state Medicaid agencies in the study plan to verify at least half of the eligibility requirements for healthcare practitioners and hospitals prior to making Medicaid electronic health record (EHR) incentive payments, the report stated. All 13 also plan to audit eligibility requirements after payment.

However, “state Medicaid agencies reported that not all of the data needed to completely verify eligibility requirements involving healthcare practitioners' patient volume are available. Few states reported plans to collect all the necessary data because the effort would be resource-intensive and logistically impractical for most states,” the report stated. “State Medicaid agencies cannot conduct complete verifications for eligibility requirements without the necessary data.”

Among the report’s findings:

  • Six of 12 states reported that the Medicaid Management Information Systems (MMIS) claims data they plan to use to verify practitioners’ Medicaid patient volume prior to payment do not reflect actual patient volume for services reimbursed at a bundled rate.
  • 10 states don’t plan to verify prior to payment whether practitioners who are practicing predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC) have a needy patient volume of at least 30 percent. “By definition, needy patient volume and total patient volume include patient volume for which Medicaid does not reimburse. As such, some states reported that practitioners’ needy patient volume and total patient volume are not reflected in states’ MMIS and states do not otherwise regularly collect this information,” the report stated.
  • Nine states don’t plan to verify prior to payment whether physician assistants (PAs) practice at PA-led FQHCs or RHCs because they do not have data that they can use to determine this. The remaining four states plan to seek alternative data sources to verify this requirement, the report stated.
  • Eight states do not plan to verify whether practitioners and hospitals actually adopted, implemented or upgraded EHRs prior to payment, because states do not have an existing data source for this. Five states plan to completely verify this eligibility requirement by having practitioners and hospitals submit documentation to demonstrate that they have adopted, implemented or upgraded EHR technology.

Click here to see the report.

 

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