EHR users, beware: the OIG is looking at you. The coming year should see an increase in OIG reviews of EHR use, according to an HCCA webinar I attended this week. Specifically, the OIG will be looking at potential inappropriate payments associated with the Medicare and Medicaid meaningful use incentive program, as well as inappropriate payments that are the direct result of the fraudulent use of EHRs. The OIG will look at incentive payments made by CMS from 2011 onward in order to identify providers who should not have qualified for the payments. Melanie Lewis, director of audit and compliance at the University of Virginia Physician's Group, said providers should make sure to retain all documentation proving their EHR meaningful use as preparation for a possible OIG review.

As for the fraudulent use of EHRs, the OIG will be looking at potential improper payments associated with cloned EHRs or pre-populated templates. Lewis Morris, an attorney at Adelman, Sheff & Smith in Annapolis, Md. and former chief counsel of the OIG, said compliance officers should pay extra attention to this issue.