A recent OIG report describes states’ plans to verify that health care practitioners and hospitals meet program eligibility requirements for state Medicaid Electronic Health Record (EHR) incentive programs for 2011 and what limitations, if any, they anticipate in their oversight. All 13 states in the OIG’s study reported that they plan to verify at least half of eligibility requirements prior to making EHR incentive payments, and to audit eligibility requirements after payment. States do not have the data needed to verify all eligibility requirements, however, which affects states’ ability to proactively ensure the integrity of their EHR incentive payments. The OIG recommends that states take these data limitations into account when planning their program oversight, such as by focusing postpayment audits on eligibility requirements that cannot be completely verified prior to payment.
