PIP/EHRIP Audits


Audits of incentive payments are a required element of the PIP/EHR Incentive Program. Providers who receive a PIP/EHR incentive payment for the Medicaid PIP/EHR Incentive Program potentially may be subject to an audit.


Vermont Medicaid PIP/EHRIP Audit Tip Sheets

The Vermont Medicaid PIP/EHRIP Audit Team has developed helpful Eligible Professional Audit Tip Sheets based on their activities and experience with reviewing provider records. Download and consult this guidance as you prepare and submit your PIP/EHRIP attestation.

Eligible Professional Audit Tip Sheet for PY2017 and PY2018 MU2 Attestations (PDF, 290 KB)

Eligible Professional Audit Tip Sheet for PY2019 and PY2020 MU3 Attestations (PDF, 310 KB)


Important Documentation Changes for Audits

As audit processes evolve, there will be changes to the supporting documentation Eligible Professionals will be required to submit. If selected for audit, providers must supply the patient volume data that supports their attestations. Audits may occur some time after an incentive payment has been received. To avoid having to retrieve or recreate the documentation, please submit your patient volume data at the time of attestation, using the the Patient Volume Data Tool. The Patient Volume Data Tool developed by the VT PIP/EHRIP Team assists in understanding and complying with the documentation requirements for supporting the Medicaid encounter threshold.

Best Practices

At the time of attestation, consolidate ancillary reports, screenshots and other types of supporting documentation for all MU measures.

Staff turnover and other activities in the course of normal priorities at a medical practice can result in a great deal of work in re-creating documentation. Ensure PIP/EHRIP-related records are kept centrally and can be easily accessed by staff in the event of future requests for at least six years.

  • Document patient volume at the time of attestation.
  • Document every Meaningful Use measure, do not rely solely on summary dashboard reports.
  • Keep supporting documentation in a central location.
  • Retain ALL relevant supporting documentation used in the completion of your PIP/EHRIP attestation for six years post-attestation. This includes documentation to support data for meaningful use objectives and clinical quality measures (CQMs), and any exclusions that were taken. Retain documentation that is in either paper or electronic format, to include screenshots.
  • Download and/or print a copy of your MU report at the time of attestation, and retain for your records. The reporting dates on your MU report should match the dates in your attestation.

More Audit Resources
  • CMS has published a guide outlining documentation requirements for audit preparation: EHR Incentive Programs Supporting Documentation for Audits (PDF, 316 KB) This is a very helpful resource to consult as you a prepare and submit an EHRIP application, and should be saved along with the documentation materials supporting the attestation.
  • At the 10/20/14 Vermont Blueprint for Health Conference, Vermont PIP/EHR Incentive Program Auditor Heather EJ Kendall gave a presentation onVermont Medicaid EHR Incentive Program Audits. You can download her presentation here.

Returning a VT PIP/EHRIP Payment

If you have any reason to return a Vermont Medicaid EHR Incentive Program payment, before being contacted regarding a payment audit, please download and follow the instructions on this form:

VT PIP/EHRIP Return Payment Form Before Audit

If you have been contacted about a PIP/EHRIP payment audit, please utilize this form to return a payment:

VT PIP/EHRIP Return Payment Form After Audit


For questions, contact the Vermont PIP/EHRIP Team at ahs.dvhaEHRIP@vermont.gov

Back to the Vermont Medicaid PIP/EHRIP Home Page

(Page last updated 07/14/2020)