Another Possible Audit, This Time for MIPS

You could receive a request in the future from the Centers for Medicare & Medicaid Services (CMS) for an audit of your Merit-Based Incentive Payment System (MIPS) submissions.

These randomly selected audits will be part of CMS’ annual data validation process, required by law, by which it ensures MIPS operates under accurate and useful data.

CMS has released a fact sheet on MIPS data validation and auditing. Audits have not yet begun, and more information from CMS is forthcoming. However, if you are selected at some point for an audit, you’ll need to respond within 10 days with sufficient documentation.

MIPS is one of two payment paths under the Medicare Access and CHIP Reauthorization Act (MACRA). Under MIPS, you show you provided high-quality, efficient care supported by technology by reporting information to CMS in four performance categories. For 2017, a transition year into full MIPS reporting, CMS will audit and validate measures and activities for the improvement activities, quality, and Advancing Care Information (ACI) categories, but not for the cost category.

Here are some pointers to keep in mind for this transition year:

MIPS improvement activities category: The documentation you use to validate your activities should demonstrate consistent and meaningful engagement within the period for which you attested. 

MIPS quality category: Data validation will apply for claims and registry submissions to validate whether you submitted all applicable measures when submitting fewer than six measures or when you do not submit the required outcome measure or other high-priority measure, or submit less than the full set of measures in the applicable specialty set.

MIPS ACI category: Under this performance category, you have some flexibility in choosing measures to report. Retain documentation to support the measures you choose to submit.

CMS has published validation criteria and suggested documentation for improvement activities and ACI measures — see MIPS Data Validation Criteria in the Resource Library on the CMS Quality Payment Program website. Keep an eye on the Resource Library for quality criteria, which CMS is expected to release.

How long should you retain documents? In accordance with the False Claims Act, CMS encourages you to keep documents up to 10 years. CMS may request any records or data retained for the purposes of MIPS for up to six years.

Visit TMA’s MACRA Resource Center for information and resources regarding MACRA and its two payment paths, MIPS and eligible alternative payment models. Bookmark TMA’s Deadline for Doctors to keep up with MIPS deadlines.

You may be exempt from MIPS reporting — find out with the CMS MIPS lookup tool

Updated Sept. 8, 2017

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Last Updated On

April 19, 2018

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