Audit Preparedness in MIPS: How Chirpy Bird Can Help
The Centers for Medicare and Medicaid (CMS), in collaboration with Guidehouse, their consulting partner, are intensifying their data validation and audit (DVA) procedures for the Merit-based Incentive Payment System (MIPS). As CMS upholds program integrity, data accuracy, and compliance, they have resumed sending out audit notices for prior performance years.
The stakes are high. Failing an audit can result in partial or complete loss of MIPS incentives, as well as potential negative payment adjustments, including severe consequences such as criminal penalties. While the initial round of audits began in mid-2019, the DVA process is ongoing.
Understanding the DVA Process
The DVA process involves the random selection of MIPS participants who will receive an audit letter from Guidehouse, initiating the audit for the MIPS Quality, Improvement Activities (IA), and Advancing Care Information (ACI)/Promoting Interoperability (PI) performance categories.
Once audited, you will have 45 days to respond to Guidehouse's initial data sharing request. Depending on the categories chosen for the audit, you may need to provide information on one or more measures or activities. Guidehouse will subsequently request patient-level data to validate the submitted reports, similar to a traditional CMS chart audit. CMS's final determinations are not subject to appeal.
In this scenario, preparation becomes your best defense.
How Likely am I to be Audited?
In the 2017 and 2018 performance years, DVAs were conducted on approximately 40% of all available MIPS measures and activities. From that 40%, the number of measures or activities selected for a DVA from each MIPS category mirrored each category's weighting for that performance year. For instance, in 2018, approximately 50% of total audits were for Quality, 15% for IA, and 25% for PI. Your specific DVA may require documentation related to one or all measures and activities you submitted for MIPS.
How Are Providers Chosen?
MIPS eligible clinicians are randomly selected for DVA. The random process includes manual input to ensure a representative sample selection that includes various clinician types (urban, rural, large, and small practices) and submission methods (EHR, QCDR, Claims, Registry, etc.). If selected for a MIPS data validation and audit, you will be notified and given an initial request for information, with 45 days to respond.
How Do I Prepare?
Since the DVA occurs at least 1-2 years after the performance year, it's advisable to gather all necessary documentation and screenshots in advance. This ensures you have the required documents if randomly audited. You can create an electronic folder structure based on how you do your MIPS attestation, either by individual provider or group, and further break it down into the MIPS reporting categories. If you report MIPS for multiple years, create a separate file for each year.
Audit Preparedness: Five Key Steps
Maintain an 'audit binder': Keep documentation for each MIPS performance category (excluding Cost), including reports from your certified EHR, related documents, and correspondence. As per the False Claims Act and CY 2019 Quality Payment Program final rule, documentation must be maintained for at least six years.
Monitor your emails: Stay vigilant and check your email addresses associated with your MIPS submission, including the spam folder. If you miss an email from Guidehouse, don't expect to receive an extension.
Complete your Security Risk Analysis (SRA): Fulfill the MIPS PI data protection measure by conducting and documenting your SRA. Be prepared to present it during an audit.
Leverage your EHR vendor: If you have any doubts about the audit process, consult your EHR vendor for guidance on generating the necessary documentation from your EHR system.
Review MIPS DVA resources: Familiarize yourself with the resources available on the Quality Payment Program Resource Library, such as the MIPS Data Validation Criteria for 2017 and 2018.
The Chirpy Bird Advantage
At Chirpy Bird, we understand the complexities of the MIPS process and the significance of audit preparedness. As part of our service, we provide a comprehensive Book of Evidence, ensuring you always have the necessary data and documentation readily available. This greatly aids in audit preparation and reduces associated stress.
Our Book of Evidence is meticulously structured with a proprietary Table of Contents for each client. This personalized approach guarantees easy access to your specific requirements and well-organized data. This custom categorization ensures quick and stress-free access to all relevant information during an audit.
By partnering with Chirpy Bird for your MIPS needs, you not only receive support for your annual MIPS strategy, performance tracking, and submissions but also gain peace of mind knowing that you have a team of MIPS experts and a comprehensive, well-structured Book of Evidence to support you if audited.
Our MIPS service is designed to make compliance as straightforward and stress-free as possible. Reach out to us today to learn more about how we can assist your practice with MIPS submissions and audit preparedness.
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With our team of MIPS experts, we offer personalized guidance and support throughout the audit process. We assist with maintaining detailed documentation, monitoring correspondence, performing SRAs, liaising with your EHR vendor, and reviewing essential MIPS resources.
With Chirpy Bird, you can focus on delivering high-quality care, knowing that your MIPS performance is in safe hands. Contact us today to learn more about how we can assist you.
Email: hello@chirpybirdinc.com Phone: 888-647-7247
