If you recall, the Texas Medical Association told you last year – and the year before that – that the Centers for Medicare & Medicaid Services (CMS) is planning to audit physicians who participate in the Merit-Based Incentive Program (MIPS), which is under the Quality Payment Program (QPP).
Well, we now know that Guidehouse, a nationwide consulting firm, will be doing the data validation and audits.
So if you submitted MIPS data for 2017 and/or 2018, you could receive a request for information via email or certified letter from Guidehouse. You will have 45 days from the date of the notice to provide the requested information.
“If you do not provide the requested information CMS may take further action, to include the possibility that you will be selected for future audits,” CMS said in a statement.
CMS says it will conduct the data validation and audit process annually to ensure the program operates with accurate and useful data.
The data submission period has ended for both years. If you didn’t take screen shots or save any records of all reports used to prepare data for submission, TMA recommends you do so now. By the time an audit comes around, your electronic health record (EHR) may be unable to re-create the same report or you may have switched EHRs.
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.
CMS is developing resources to help physicians who are selected to participate.
In the meantime, the CMS Quality Payment Program Resource Library contains the 2017 and 2018 criteria used to audit and validate data submitted in each performance category.
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.
TMF Health Quality Institute provides free QPP support if you need answers to your audit or other MIPS-related questions.
And you can always stay up to date on the latest MIPS and QPP news on TMA’s online MACRA Resource Center.