There is room for improving how the government measures whether hospitals and physicians have met the requirements for meaningful use of EHRs to prevent improper payments, according to the U.S. Government Accountability Office (GAO).

GAO made four recommendations to CMS in order to improve processes to verify whether providers met program requirements for the Medicare and Medicaid EHR programs, including opportunities for efficiencies. HHS agreed with three of GAO’s recommendations, but disagreed with the fourth – that CMS offer to collect certain information on states’ behalf. GAO continues to believe this action is an important step to yield potential cost savings, GAO officials said in their report.

GAO recommendations aim to improve the efficiency and effectiveness of processes to verify whether providers meet program requirements for the Medicare and Medicaid EHR programs.

1. The administrator of CMS should establish time frames for expeditiously implementing an evaluation of the effectiveness of the agency’s audit strategy for the Medicare EHR program.
2. The administrator of CMS should 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.
3. The administrator of CMS should collect the additional information from Medicare providers during attestation that CMS suggested states collect from Medicaid providers during attestation.
4. The administrator of CMS should offer states the option of having CMS collect meaningful use attestations from Medicaid providers on their behalf.

To receive incentive payments, providers must meet both eligibility requirements that specify the types of providers eligible to participate in the programs and reporting requirements that specify the information providers must report to CMS or the states, including measures that demonstrate meaningful use of an EHR system and measures of clinical quality.

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.

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 have implemented primarily prepayment processes to verify whether providers met all eligibility requirements. To verify the reporting requirement, all four states implemented prepayment processes, postpayment processes,

CMS officials stated that 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, according to GAO.

Such an evaluation could help CMS determine whether it should revise its verification processes by, for example, implementing additional prepayment processes, which GAO has shown may reduce the risk of improper payments. In addition, CMS has opportunities to improve the efficiency of verification processes by, for example, collecting certain data on states’ behalf, or both.