Audit Preparedness in MIPS: How Chirpy Bird Can Help
The Center for Medicare and Medicaid (CMS) have heightened their data validation and audit (DVA) process for the Merit-based Incentive Payment System (MIPS). Ensuring data accuracy and compliance is crucial to avoid audits. Failing an audit can result in partial or complete loss of MIPS incentives, as well as negative payment adjustments.
The DVA Process
The DVA process is conducted through the selection of random MIPS participants, who will receive an audit letter from Guidhouse, initiating the audit for MIPS Quality, Improvement Activities (IA), and Advancing Care Information (ACI)/Promoting Interoperability (PI) performance categories.
Once audited, you will have 45 days to give a response to the initial data sharing request. Depending on which category is chosen for the audit, additional information and documentation on one or more measures or activities may need to be provided. Examples of pieces of documentation include copies of claims or other resources used in the data calculations for MIPS measures and activities. Data will be submitted through email, facsimile, or through electronic routes via a secure website maintained by CMS.
How Are Providers Chosen?
Providers that are chosen for DVA are selected at random. The 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).
How Likely Am I to be Audited?
During the 2017 and 2018 performance years, about 40% of all MIPS measures and activities underwent DVAs. Within this 40%, the distribution of audited measures and activities corresponded to each MIPS category's weighting for that year. For example, in 2018, roughly 50% of the audits focused on Quality, 15% on Improvement Activities (IA), and 25% on Promoting Interoperability (PI). If you are selected for a DVA, you may need to provide documentation for one or more measures and activities you submitted for MIPS.
How do I prepare?
To prepare for the DVA process, it is advisable to gather all necessary documentation in advance. This ensures that all required documents are readily available in the event of a random audit.
Five Key Steps to Stay Prepared
Maintain an Audit Binder: Organize documentation for each MIPS performance category (excluding Cost) with reports from your certified EHR, relevant documents, and correspondence. According to the False Claims Act and the CY 2019 Quality Payment Program final rule, retain these records for at least six years.
Monitor Your Emails: Regularly check emails associated with your MIPS submission, including the spam folder, to avoid missing crucial communications from Guidehouse, as extensions are not guaranteed.
Complete Your Security Risk Analysis (SRA): Conduct and document your SRA to meet the MIPS PI data protection measure, ensuring it's available for audit review.
Leverage Your EHR Vendor: Seek guidance from your EHR vendor on generating necessary documentation for audits.
Review MIPS DVA Resources: Familiarize yourself with the MIPS Data Validation Criteria and other resources in the Quality Payment Program Resource Library.
The Chirpy Bird Advantage
At Chirpy Bird, we understand the complexities of the MIPS process and the significance of audit preparedness.
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 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.
Our MIPS service is designed to make compliance as straightforward and stress-free as possible.
Call or Email Us Today for a FREE Service Quote
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.
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