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Program Integrity & Audit

The Division of Health Care Finance & Administration (HCFA) is required to ensure the integrity and effectiveness of Tennessee’s Medicaid EHR Incentive Payment Program. In order to fulfill this requirement, HCFA has developed processes for both prepayment verification and post payment audits of provider attestations. Upon submitting an attestation, the provider, or the person attesting on behalf of the provider, affirms that the attestation is true, accurate, and complete, to the best of his/her knowledge and belief.

Prepayment Verifications

HCFA has implemented stringent prepayment verification procedures to ensure the accuracy of the information submitted as part of the EHR attestation. Many aspects of the eligibility requirements and achievement of meaningful use are verified prior to the payment of any EHR incentive. Complete and correct attestations are paid within 30-45 days. Attestations identified by the prepayment verification process as being incomplete or incorrect are electronically returned to the provider with detailed guidance and instructions, where applicable, to address the issue(s). Follow the links below for information and resources to facilitate successful participation and attestation.

If you have questions about the prepayment verification process, contact: TennCareEHRIncentive@tn.gov regarding eligibility requirements; and EHRMeaningfulUse.TennCare@tn.gov regarding meaningful use requirements.

Post Payment Audits

HCFA’s Office of Audit & Investigations is responsible for performing EHR post payment audits for Adopt, Implement or Upgrade (AIU) and Meaningful Use (MU).  The primary objective of a post-payment audit is to determine the appropriateness and accuracy of the EHR incentive payment. All payments received are potentially subject to audit.

An audit may take the form of either a desk audit or an onsite audit. Written notice will be given to the provider or the appropriate contact person prior to beginning an audit.  

The provider may be asked to provide documentation to support any of the information in the attestation.  In many cases, the information can be reproduced by generating system reports, etc.  If any information used for the attestation cannot be systematically reproduced, a copy of the original documentation should be maintained.  This includes data supporting Medicaid patient volume and or MU measures at the patient level.  In light of the possibility of a post payment audit, providers are required to retain documentation to support all attestations for no fewer than six years after each payment year.

If you have questions about the post payment audit process, contact: tenncareinternalaudit.ehr@tn.gov.