Post-Payment Audit Guidance


Providers selected for a post–payment audit will be required to provide documentation that verifies the Adoption/Implementation/Upgrade (AIU) of their complete certified Electronic Health Record (EHR) system. Below are explanations and documentation requirements for AIU audits. Please note that additional documentation will be requested in the Audit Notification Letter to support eligibility for the incentive program (e.g., documentation to support a qualifying Medicaid patient volume).

The payment year, as well as the reporting periods for MU and patient volume, is selected by the provider or authorized person during the online attestation process. All providers should be prepared to supply documentation to support that their activities during the payment year and selected reporting periods met the definition of the activities to which they attested. For example, an attestation for AIU for payment year 2016 may be submitted in 2017, but the supporting documentation must show that the AIU activity attested to was performed by the provider during payment year 2016.

Adoption/Implementation/Upgrade (AIU)

In their first payment year, providers may attest that they have adopted, implemented, or upgraded to certified EHR technology. According to the Final Rule, "Section 1903(a)(3)(F)(i) of the Act, as amended by section 4201 of the HITECH Act, establishes 100 percent FFP to States for providing incentive payments to eligible Medicaid providers (described in section 1903(t)(2) of the Act) to adopt, implement, upgrade, and meaningfully use certified EHR technology. The incentive payments are not direct reimbursement for the purchase and acquisition of such technology, but rather are intended to serve as incentives for EPs and eligible hospitals to adopt and meaningfully use certified EHR technology".
        Source: Federal Register / Vol. 75, No.144/ Rules and Regulations Page 44482

Adopt means to acquire, purchase, or secure access to certified EHR technology. It is not necessary that the certified EHR technology be installed or in active use in the clinical setting, so long as the provider can demonstrate a financial commitment to purchasing or using the certified EHR technology during the payment year. Documentation to support this could include payment receipts, signed vendor contract, leases, or proof of the acquiring of the system. In cases where the EHR system is free or a financial exchange cannot be demonstrated, the provider will be required to submit documentation that shows installation or access to the system.

Implement means to commence usage of a certified EHR technology capable of meeting Meaningful Use requirements. It is not necessary to demonstrate that implementation is complete or that the EHR system is in active use in the clinical setting; however, plans to implement the certified EHR technology are not sufficient. The provider also needs to show examples of adopting the technology. Examples of activities that may be sufficient to demonstrate implementation include:

  • Progress in integrating the certified EHR system with existing systems
  • Execution of staff training on the certified EHR technology
  • Progress in transition to the certified EHR technology, such as entry of existing patient data into the EHR system

Upgrade means to expand the available functionality of certified EHR technology capable of meeting Meaningful Use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology. If the provider is upgrading from a previous version of the EHR technology to a certified version, or adding modules to achieve a complete certified system, the same documentation criteria applies as for adoption of a new EHR system. If the provider is upgrading custom EHR technology to achieve certification, the following are examples of documentation that would be sufficient to demonstrate upgrade:

  • Signed contract with vendor, developer, or systems integrator for services to upgrade the EHR technology
  • Copy of paid invoice that clearly identifies the EHR technology and indicates the services rendered