The Centers for Medicare and Medicaid Services (CMS) announced that, starting in January 2023, it would begin auditing clinicians for the Merit-Based Incentive Payment System (MIPS) 2019, 2020, and 2021 performance years.
Retain MIPS data
MIPS-eligible clinicians, the subject of the forthcoming audits, include clinicians who are eligible to receive a MIPS payment adjustment. All MIPS-eligible clinicians who submit data and information to CMS for purposes of MIPS must certify to the best of their knowledge that the data submitted is true, accurate, and complete. All MIPS eligible clinicians who submit data and information to CMS for purposes of MIPS must retain such data and information for six years from the end of the MIPS performance period. Traditional MIPS comprises four performance categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. Performance across these MIPS categories results in a MIPS final score, which determines whether CMS applies a negative, neutral, or positive MIPS payment adjustment.
MIPS data validation and audits
The data validation and audit process are intended to confirm the accuracy and completeness of reported results of the MIPS program. The data validation and audits will cover the Quality, Improvement Activities, and Promoting Interoperability performance categories. The Cost performance category will not be included in the data validation and audits.
For the 2019, 2020, and 2021 performance years, CMS has contracted with Guidehouse to audit MIPS eligible clinicians. These clinicians will be selected randomly. If selected for a MIPS data validation and audit, Guidehouse will send an email request for information, and the recipient of the request must provide the requested information within 45 days of the date of the notice. Requested information may include copies of claims; medical records for applicable patients; or other resources used in the data calculations for MIPS measures, objectives, and activities. Failure to provide the requested information could result in a payment adjustment. Failure to respond may also increase the possibility that you will be selected for future data validation and audits.
How to Prepare
- Ensure that your contact information is accurate in the Healthcare Quality Information Systems Access Roles and Profile platform.
- Monitor your email for requests from MIPS_DVA@guidehouse.com. Participants selected for the data validation and audit will be notified via the email address associated with the MIPS submission’s Tax ID Number.
- Notify whoever monitors that email address to be on the lookout for the Guidehouse email. Advise them to forward the email immediately to a designated person.
- If selected for a data validation and audit, observe the critical deadline, and begin to gather requested documentation as soon as possible.
- Review the MIPS Data Validation Criteria for 2019, 2020, and 2021 if further clarification is needed.
- Participants selected for the data validation and audit will submit information through a secure file sharing platform or via secure fax. The participant may designate someone to submit the information on their behalf (including other office staff, Electronic Health Record, Qualified Registry, Qualified Clinical Data Registry, other contractors, etc.).
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
