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Audits and Appeals Overview

Beginning in 2019, all eligible professionals (EPs), eligible hospitals, dual-eligible hospitals, and critical access hospitals (CAHs) are required to use 2015 edition certified electronic health record technology (CEHRT) to meet the requirements of the Promoting Interoperability Program. Note that the requirements for eligible hospitals, dual-eligible hospitals, and CAHs that submit an attestation to CMS under the Medicare Promoting Interoperability Program were updated in the 2019 IPPS final rule.

In 2019, all Medicaid eligible hospitals and EPs must adhere to the requirements of their state’s Medicaid Promoting Interoperability Program and attest directly to their state. Visit the 2019 Promoting Interoperability Medicaid page for more information.

Promoting Interoperability Programs Audit Overview

All Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the Promoting Interoperability 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.

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.

Medicare Promoting Interoperability Program Appeal Overview

CMS has an appeals process for all providers that use certified electronic health record technology to participate in the Medicare Promoting Interoperability 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 Promoting Interoperability Programs.

Appeal inquiries and submissions can be sent to EHRinquiries@cms.hhs.gov.

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