The State of New Jersey will perform pre- and post-payment monitoring to ensure that incentive payments are paid in accordance with all Federal and State regulations and policies. Hospitals should keep all documentation supporting attestation for 6 years in the event of an audit.
Prior to issuing payment, all attestations will be reviewed based on information provided through the New Jersey Medicaid EHR Incentive Program Attestation Application. These reviews will include electronic inquiries and manual reviews using available data sources such as the hospital’s claims and encounter data stored in the New Jersey Medicaid Management Information System (MMIS) as well as other State databases and registries.
Pre-payment checks will be made to verify the following:
· The hospital is enrolled in New Jersey Medicaid.
· The hospital is licensed and was licensed for the applicable time frame with no suspensions or revocations (including pharmaceutical prescribing licensure).
· The provider’s Tax Identification Number (TIN) has been verified by matching with an IRS TIN
· The minimum patient volume threshold is achieved from a check of claims volume and the supporting information submitted.
· No previous year payment was made, for the hospital claiming incentives based on adoption, implementation, or upgrading (AIU) or meaningful use of EHR technology.
· The hospital successfully met the requirements of adopting, implementing or upgrading or meaningful use of certified EHR technology.
· The acute care hospital average length of stay is less than 25 days for the relevant time period.
The federal government will perform additional pre-payment checks once the State has accepted a provider's attestation. The federal government may also, upon their discretion, perform post-payment audits in addition to the audit performed by the State contracted auditors, Mercadien P.C. Certified Public Accountants.
After the payment is issued, each hospital will have an onsite inspection of the documentation supporting their original attestations and other eligibility criteria. Original documentation to be tested will include, but not be limited to, the documents that support the following information used to calculate the incentive payment:
· Total acute inpatient discharges for the last 4 completed hospital fiscal years
· Total acute inpatient bed days for the entire hospital fiscal year completed in the most recently completed federal fiscal year
· Acute inpatient bed days which Medicaid (Title XIX only, fee-for-service or managed care) paid a share of for the same hospital fiscal year, excluding Medicaid/Medicare dual eligible days
· Total charges for the hospital fiscal year completed in the most recently completed federal fiscal year
· Total Charity Care charges for the hospital fiscal year completed in the most recently completed hospital fiscal year
The documentation supporting the adoption, implementation, or upgrade to or meaningful use of certified EHR technology will also be reviewed. Representatives of Mercadien P.C. Certified Public Accountants, will perform these onsite inspections and report the findings to the New Jersey Division of Medical Assistance and Health Services.
If an audit determines that an error in payment has been made, a written notification will be created and sent, informing the hospital of the intent to recover funds. The recovery process will follow current New Jersey Division of Medical Assistance and Health Services recovery practices and guidelines.