Do states need to verify the "installation" or "a signed contract" for adopt, implement or upgrade (AIU) in the Medicaid EHR Incentive Program?

States should make clear to providers when they attest for adopt, implement or upgrade (AIU) what documentation they must maintain, and for how long, in case of audit. If states determine that certain provider types are a high risk for potential fraud/abuse for AIU, then they can ask for some verification of adopting, implementation or upgrading. However, CMS encourages that this be done in a targeted manner, with the most electronic and simple means possible and not in such a way that would be burdensome to providers. For AIU, a provider does not have to have installed certified EHR technology. The definition of AIU in 42 CFR 495.302 allows the provider to demonstrate AIU through any of the following:
(a) acquiring, purchasing or securing access to certified EHR technology capable of meeting Meaningful Use.
(b) installing or commencing utilization of certified EHR technology capable of meeting Meaningful Use requirements.
(c) expanding the available functionality of certified EHR technology capable of meeting Meaningful Use requirements at the practice site, including staffing, maintenance and training, or upgrade from existing EHR technology to certified EHR technology per the EHR certification criteria published by the Office of the National Coordinator of Health Information Technology (ONC).
Thus, a signed contract indicating that the provider has adopted or upgraded would be sufficient.