MIPS Audit? Here’s What You Need to Know
By David Doolittle


Are you planning to submit data to the Merit-Based Incentive Payment System (MIPS) under the 2018 Quality Payment Program (QPP)? If so, the Centers for Medicare & Medicaid Services (CMS) could tap you for a MIPS audit in the future. Here are some things to know to prepare your practice.

To begin, if you’re not sure if you’re required to submit MIPS data for 2018, check your QPP participation status on the QPP website

The Texas Medical Association has not heard of any current audit activity, but all participating physicians should prepare their practices for the possibility of being selected for an audit. 

The 2018 QPP performance year will end Dec. 31. As you prepare to submit data, know that all MIPS data that you or your vendor submit will be subject to what CMS calls “data validation and auditing.” TMA recommends that you take screen shots and save copies of all reports used to prepare data for submission. By the time an audit comes around, your electronic health record (EHR) may be unable to recreate the same report or you may have switched EHRs.

The window to submit 2018 MIPS data to CMS will open Jan. 2 and close April 2. You will be able to submit or resubmit MIPS data through the QPP portal at any time during that window. With each submission, you must certify that data is true, accurate, and complete. 

CMS says it will conduct the data validation and audit process annually to ensure the program operates with accurate and useful data. Because MIPS audits are required by law, if you are selected by CMS or its designated entity, you will be required to comply with all data-sharing requests.  

To be in compliance, you must keep documentation for up to six years for the MIPS quality, promoting interoperability, and improvement activities categories for every performance year you participate in the program. Because your score for the cost category is calculated using information derived directly from Medicare claims data, the cost category is excluded from MIPS audits.   

Under the QPP, CMS refers to MIPS-related vendors as “third party intermediaries.” That includes qualified registry vendors, qualified clinical data registry vendors, health information technology or EHR vendors, and survey vendors. These vendors must comply with several requirements to participate in MIPS, including keeping records for auditing purposes that are separate from MIPS audits for physician practices. If you use a vendor, CMS encourages you to retain your own records as well.   

For complete details about the data validation and auditing process, and the records and documentation requirements for each MIPS category, TMA recommends you download CMS’ 2018 MIPS Data Validation Criteria (zip file) and read the FAQs from TMF Health Quality Institute

To participate in a live Q&A session, register for TMF’s Audit Readiness for MIPS webinar scheduled from noon to 1 pm Wednesday, Nov. 21. For free QPP support, contact TMF to get answers to your audit or other MIPS-related questions. 

For in-person quality improvement services and tailored practice support to help you succeed in all things MIPS, turn to TMA Practice Consulting. Email practice.consulting[at]texmed[dot]org or call (800) 523-8776 to learn more.

And you can always stay up to date on the latest MIPS and QPP news on TMA’s online MACRA Resource Center.

Last Updated On

November 19, 2018

Originally Published On

November 15, 2018

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