MACRA/MIPS: The Audits Cometh
Sooner or later we knew it was coming. It was just a matter of time until CMS started cranking up the audit process for the MACRA/MIPS program. During the Meaningful Use (MU) EHR Incentive Program both Medicare and Medicaid recipients faced audits. In cases where either eligible providers or eligible hospitals failed an audit, the entire incentive for a particular year was recouped. There is the potential for much more to be at stake this time as the recoupments could be considerable higher if an audit is failed.
Here is what is known, direct from CMS:
Merit-based Incentive Payment System (MIPS) Data Validation and Audit to begin June 2019 for Performance Years 2017 and 2018
The Centers for Medicare & Medicaid Services (CMS) has contracted with Guidehouse to conduct data validation and audits of a select number of Merit-based Incentive Payment System (MIPS) eligible clinicians. Data validation and audits are processes that will help ensure MIPS is operating with accurate and useful data. MIPS eligible clinicians, groups and virtual groups are required by regulation to comply with data sharing requests, providing all data as requested by CMS.
If you are selected for data validation and/or audit, you will receive a request for information from Guidehouse. It will be sent via email or by certified mail. Please be on the lookout for this notification. You will have 45 calendar days from the date of the notice to provide the requested information.
Please note, 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. To help avoid this, we are in the process of developing resources to support clinicians selected to participate.
We currently have the following data validation and audit resources available on the Quality Payment Program Resource Library:
- 2017 MIPS Data Validation Criteria – Lists the 2017 criteria used to audit and validate data submitted in each performance category
- 2018 MIPS Data Validation Criteria – Lists the 2018 criteria used to audit and validate data submitted in each performance category