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Program Integrity & Audit

TennCare is required to ensure the integrity and effectiveness of Tennessee’s Medicaid EHR Incentive Payment Program. In order to fulfill this requirement, TennCare 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

TennCare 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

TennCare’s Division 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 of the EHR incentive payment received by an Eligible Professional (EP) or an Eligible Hospital (EH) based on meeting eligibility requirements for AIU/MU and attaining meaningful use.  All payments received by an EP or an EH are potentially subject to audit.

EPs and EHs are selected for audit based on risk assessment and random sampling.  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 onsite or desk audit.  For a desk audit, the provider will be asked to submit any information that will be needed to complete the audit within two weeks from the date of the notice.  For an onsite audit, the provider will be asked to schedule the audit for a date within two weeks from the date of the notice. 

The provider may be asked to provide documentation to support any of the information in his/her attestation for adopting, implementing, or upgrading (AIU) certified EHR technology and/or meaningful use (MU) of that technology.  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 documentation may be in the form of vendor communications, screenshots, etc.  In light of the possibility of a post payment audit, providers are required to retain documentation in support of 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.