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Early Assessment Finds That CMS Faces Obstacles in Overseeing the Medicare EHR Incentive Program


This study is an early assessment of CMS's oversight of the Medicare electronic health record (EHR) incentive program, for which CMS estimates it will pay $6.6 billion in incentive payments between 2011 and 2016. Because professionals and hospitals self-report data to demonstrate that they meet program requirements, CMS's efforts to verify these data will help ensure the integrity of Medicare EHR incentive payments.


This study reviewed CMS's oversight of professionals' and hospitals' self-reported meaningful use of certified EHR technology in 2011, the first year of the program. To address our objective, we analyzed self-reported information to ensure it met program requirements. We also reviewed CMS's audit planning documents, regulations, and guidance for the program and conducted structured interviews with CMS staff regarding CMS's oversight.


CMS faces obstacles to overseeing the Medicare EHR incentive program that leave the program vulnerable to paying incentives to professionals and hospitals that do not fully meet the meaningful use requirements. Currently, CMS has not implemented strong prepayment safeguards, and its ability to safeguard incentive payments postpayment is also limited. The ONC requirements for EHR reports may contribute to CMS's oversight obstacles.


We recommend that CMS: (1) obtain and review supporting documentation from selected professionals and hospitals prior to payment to verify the accuracy of their self reported information and (2) issue guidance with specific examples of documentation that professionals and hospitals should maintain to support their compliance. CMS did not concur with our first recommendation, stating that prepayment reviews would increase the burden on practitioners and hospitals and could delay incentive payments. We continue to recommend that CMS conduct prepayment reviews to improve program oversight. CMS concurred with our second recommendation.

We recommend that ONC: (1) require that certified EHR technology be capable of producing reports for yes/no meaningful use measures where possible and (2) improve the certification process for EHR technology to ensure accurate EHR reports. ONC concurred with both recommendations.