On October 11, 2012, The OIG distributed a questionnaire to hospitals that have received Medicare EHR incentive payments for demonstrating meaningful use of its certified EHR technology. This questionnaire is being sent to hospitals that have received incentive payments between January 1, 2011 and March 31, 2012 which amounts to approximately 830 hospitals nationwide. The authority for this study is found in 5 U.S.C. App. 3 at §2,4 and 6 of the Act, which authorizes the Inspector General to conduct inquiries and make recommendations relating to the economy, efficiency and effectiveness of programs administered or funded by the U.S. Department of Health and Human Services.
The topics focused on are user authorization and access, audit logs, metadata, entry of physician progress notes and patient identity management. Although some of these elements are not yet mandatory, it is expected that hospital responses will help inform future meaningful use requirements and EHR technology policy.
While this initial questionnaire is being directed to a limited number of hospitals nationally, it is anticipated that the government's interest will be directed at all recipients of meaningful use revenue. Providers should review their HIPAA privacy and security policies, to ensure they are consistent with all applicable regulatory requirements.