Health Information Technology for Economic and Clinical Health (HITECH) Audits

Overview

The American Recovery & Reinvestment Act of 2009 (ARRA, or Recovery Act), established the Health Information Technology for Economic Clinical Health Act (HITECH Act), which requires that CMS provide incentive payments under Medicare and Medicaid to “Meaningful Users” of Electronic Health Records. The Medicare Administrative Contractors (MACs) audit data elements used for the final HITECH payment, which is made at final settlement of the cost report. CMS issued the HITECH Desk Review and Audit Program to MACs, which includes the review steps required for the data elements used in the incentive payment calculation. CMS informs the MACs of the hospitals and issues to review. If a MAC becomes aware of an issue that materially impacts the incentive payment at a specific hospital, the MAC informs CMS so it can be included in the audit plan. MACs may choose to perform the HITECH audits at the same time as the other cost report issues or separately, depending on their current audit plan and available resources.

During the cost report final settlement process, the MACs enter the updated data elements into FISS, in order for the HITECH payment to be adjusted. The cost report includes the data for the incentive payment, and the cost report will also calculate the payment amount. Prior to issuing the NPR, the MACs ensure that the cost report amount equals the FISS amount. Any discrepancies are communicated to CMS. The MAC pays or demands the Part A and Part B underpayment or overpayment from the cost report. The MACs do not pay or demand the HITECH underpayment or overpayment, as this is handled by the Payment File Development Contractor (PFDC).

Related links are for HITECH Audits and Appeals.