The Department of Health and Human Services' Office of Inspector General (OIG) has announced in its 2012 work plan that it intends to take a much closer look at violations of fraud and abuse in electronic health record use.
OIG's 2012 work plan, released October 5, outlines the office's current focus areas and primary objectives. For the first time, OIG plans to "identify fraud and abuse vulnerabilities in electronic health record...systems as articulated in literature and by experts and determine how certified EHR systems address these vulnerabilities."
The 2012 work plan also states that OIG will review Medicare and Medicaid EHR incentive payments to providers to prevent erroneous payments. The agency will review Medicare incentive payment data from 2011 to identify payments to providers that should not have been made (e.g., those not meeting selected Meaningful Use criteria).
In addition, OIG will continue to review multiple evaluation and management services for the same providers, and beneficiaries to identify EHR documentation practices associated with potentially improper payments. This target was identified in both the 2011 and the 2012 work plans.
"Medicare contractors have noted an increased frequency of medical records with identical documentation across services," OIG notes in the 2012 plan. "Medicare requires providers to select the code for the service based upon the content of the service and have documentation to support the level of service reported."