As the end of the federal fiscal year rapidly approaches, so does the attestation deadline for hospitals participating in the Medicare Electronic Health Record (EHR) Incentive Program.

Each year, hospitals are required to show that they are “meaningfully using” their EHRs in order to receive their incentive payment and avoid any adjustment. They demonstrate such meaningful use by meeting certain objectives established by CMS. The attestation deadline for hospitals participating in the Medicare EHR incentive program is November 30, 2013.

For hospitals reporting on their first year of participation, the performance period is 90 days, while hospitals in their second or third year of participation are required to report using a full fiscal year of data. In order to benefit fully from the EHR incentive program, hospitals paid under the inpatient prospective payment system must attest to meaningful use by fiscal year 2013.

Participants in Medicare and Medicaid’s EHR incentive programs have been under increasing scrutiny as auditors are now seeking documentation to substantiate compliance with program requirements at the time of attestation. As previously reported, some providers that have been unable to produce screen shots to document their compliance have been asked to return incentive payments.

In today’s heighted enforcement environment, all providers, including hospitals and physicians, should maintain detailed records relating to their implementation and meaningful use of EHR technology. These records should include screen shots on the date of attestation that demonstrate compliance, so that this information is readily available in the event of a future audit. Hospitals that are not able to document compliance risk losing all or a portion of their EHR incentive payments.