Myers and Stauffer’s CMS-approved EHR Incentive Program Audit Strategy can be adapted to fit your State’s EHR Incentive Program.

EHR Audit Strategy


Myers and Stauffer can help you develop an effective audit strategy which takes into account the unique operations specific to your state in administering the EHR Incentive Program. The Centers for Medicare and Medicaid Services (CMS) made Myers and Stauffer’s audit strategy available in an online toolkit as a benchmark for states to follow. However, one size does not fit all! CMS allows states flexibility in many areas of EHR Incentive Program operations.

Developing an approved audit strategy is only a small step in a complicated maze of program oversight. States cannot simply propose activities in their State Medicaid Health Information Technology Plan (SMHP). States are responsible for ensuring that those processes are carried out to verify that providers have:

  • Calculated patient volume accurately.
  • Adopted, implemented, or upgraded certified EHR technology.
  • Utilized appropriate auditable data sources for payment calculations.
  • Reported meaningful use measures and clinical quality measures (CQM) correctly.

We have been helping clients since the EHR Incentive Program was launched nationally. We understand the difficulties associated with fulfilling these responsibilities. We have developed analytical tools necessary to efficiently conduct post-payment desk reviews and on-site audits of AIU and Meaningful Use. We have developed pre-payment tools such as calculators to assist both Eligible Hospitals and Eligible Professionals in determining whether they meet minimum eligibility requirements. Our team will help design an audit strategy to incorporate the impact on risk resulting from changes in your program.

In addition to conducting post-payment audits, Myers and Stauffer will review your program operations and make recommendations for appropriate audit coverage, including how to account for CHIP claims for integrated programs. We will also make recommendations on effective strategies for dealing with FQHC/RHCs and physician global codes. Our recommendations will include how to improve efficiencies in pre-payment reviews, maintain program year specific information, such as 90-day or 365-day EHR reporting periods and other information necessary to ensure proper payment. We have the expertise to audit all information under attestation while incorporating the impact on risk resulting from changes in your program.


Myers and Stauffer was recognized by CMS for best practice standards for EHR audits.