American Osteopathic Association

Advancing the distinctive philosophy and practice of osteopathic medicine

Medicare or Medicaid Meaningful Use Audits

‚ÄčIf you have participated in the Medicare or Medicaid Electronic Health Record (EHR) Incentive Program and have attested to meaningful use to receive an incentive payment, you may be subject to an audit.

The Centers for Medicare and Medicaid Services (CMS), and its contractor, Figliozzi and Company are performing audits on Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the EHR Incentive Programs. States, and their contractor, will perform audits on Medicaid providers participating in the Medicaid EHR Incentive Program.

If you are audited, the request letter will be sent electronically by Figliozzi and Company from a CMS email address to the email address provided during registration for the EHR Incentive Program. The initial review process will be conducted using information provided in response to the request letter, which may request additional information such as:

  • A copy of the HHS certificate¬† to verify¬† that the eligible professional met the CMS EHR Incentive Program Meaningful Use requirements

  • Documents to support how the physician reported emergency room admissions

  • EHR documents to support that attestation was complete for the measure set objectives and voluntarily selected objectives

  • If you receive an audit letter:

  • Respond immediately and request additional time to review and gather records

  • Confirm the claims are yours

  • Provide only the requested documentation

  • Ensure that your information is HIPAA-compliant

  • Send the requested information by certified letter with return receipt requested

After an audit, if Figliozzi & Company determines the physician is not eligible for an EHR incentive payment, the incentive payment will be recouped. CMS believes that providers who relied on defective software to attest to meaningful use acted in good faith and would have met criteria using an updated certified EHR system, so those providers will not be penalized.

Appealing an Audit

For general questions on how to file appeals regarding the Medicare EHR Incentive Program and/or the status of any pending appeals, contact the EHR Information Center at (888) 734-6433 between 9 a.m. and 5 p.m. EST, Monday through Friday.

For Medicaid EHR Incentive Program appeals information, contact your state Medicaid agency appeals department.


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