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Audits and Appeals Overview

CMS is renaming the EHR Incentive Programs to the Promoting Interoperability (PI) Programs to continue the agency’s focus on improving patients’ access to health information and reducing the time and cost required of providers to comply with the programs’ requirements. CMS is also in the process of finalizing updates to the programs through rulemaking. For more information, visit the landing page where CMS will publish updates and additional resources as soon as they are available.

Promoting Interoperability Programs Audit Overview

All Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the PI Programs may be subject to an audit by CMS and its contractor, Figliozzi and Company. States, and their contractor, will perform audits on Medicaid providers participating in the Medicaid PI Program.

The 2015 and 2016 PI reporting periods included alternate exclusions and specifications for some objectives and measures where there was not a Stage 1 measure equivalent to the Modified Stage 2 (2015 through 2017) measure or where a menu measure became a requirement. CMS will not require documentation that a provider did not plan to attest to a menu objective for the provider to claim the alternate exclusion.

Additional information, including an overview of the audit process can be found in the EHR Incentive Programs Audits Overview fact sheet.

Preparing and Maintaining Supporting Documentation
Providers should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses for six years post-attestation.

 PI Program Appeal Overview

CMS has an appeals process for all providers that use certified electronic health record technology to participate in the Medicare PI Program, but were unable to successfully register or attest to meaningful use. A designated contractor accepts appeals on behalf of CMS for Medicare eligible professionals and eligible hospitals, as well as hospitals that are dually-eligible for the PI Programs.

Appeal inquiries and submissions can be sent to

Additional information, including an overview of the appeal process can be found in the EHR Incentive Programs Appeals Overview fact sheet.