In June, the Centers for Medicare & Medicaid Services (CMS) announced the commencement of audits for the Merit-based Incentive Payment System (MIPS). The contract was awarded to Guidehouse, formerly known as the US Public Sector of PricewaterhouseCoopers. Guidehouse is transmitting notifications of audits via email or certified mail. The auditors require the requested information be provided within 45 calendar days.
CMS has issued guidance about the requirements to fulfill the audit. For example, the 2017 “Provide Patients Access” criteria, which was a component of the Advancing Care Information category requires: “Dated report, screenshot, or other information that documents the number of times a patient or patient authorized representative is given access to view, download, or transmit their health information. This could include instructions provided to the patient on how to access their health information including the website address they must visit, the patient's unique and registered username or password, and a record of the patient logging on to show that the patient can use any application of their choice to access the information and meet the API technical specifications.”
The guidance about the audit requirements, which can be accessed in the Quality Payment Program’s online resource library, are titled: “MIPS Data Validation Criteria.” The 2017 and 2018 versions have been posted here. CMS advises that documentation about the Merit-based Incentive Payment System should be maintained for six years. It’s an opportune time to review this newly released guidance to ensure your documentation strategy for program compliance is responsive to the new guidelines. Should you be audited, you’ll be ready.
Elizabeth Woodcock is the founder and principal of Woodcock & Associates. She has focused on medical group operations and revenue cycle management for more than 20 years and has led educational sessions for the Medical Group Management Association, the American Congress of Obstetricians & Gynecologists, and the American Medical Association. She has authored and co-authored many books. She is frequently published and quoted in national publications including The Wall Street Journal, Family Practice Management, MGMA Connexion, and American Medical News. Elizabeth is a Fellow in the American College of Medical Practice Executives and a Certified Professional Coder. In addition to a Bachelor of Arts from Duke University, she completed a Master of Business Administration in healthcare management from The Wharton School of Business of the University of Pennsylvania.