CMS Beginning MIPS Audits for 2019 through 2021
The Centers for Medicare & Medicaid Services (CMS) has contracted with Guidehouse, a third-party company, to conduct a data validation and audit of the Merit-based Incentive Payment System (MIPS) for the 2019, 2020, and 2021 performance years. This is the second DVA conducted since the start of the MIPS program in 2017.
Clinicians who are selected for the audit will be notified via email from MIPS_DVA@guidehouse starting this month and should be prepared to respond fully to provide any requested information. All data submission methods are eligible for audit – which encompasses Medicare Claims-based submissions, MIPS CQM (Registry), MIPS eCQM (EHR), or CMS Web Interface data submissions.
If chosen for an audit, clinicians will have 45 days from the date of notice to provide the requested information, which may include copies of claims, medical records for applicable patients, and other resources used in the data calculations for MIPS measures, objectives, and activities.
An instructional video is available HERE on how to submit data if selected for the audit.
General advice for complying with current or future MIPS DVA requests include:
- Keeping documentation for six years
- Maintain up-to-date, accurate information related to the Medicare Provider Enrollment, Chain, and Ownership System (PECOS)
- This includes your practice email address, where any notice will be sent.
- Document everything by saving screenshots in a safe space
CMS warns that failure to provide all requested information may result in a payment adjustment or an increased chance of being selected for data validation and audits in the future.
As always, ADVOCATE will keep you up to date on this and all issues impacting medical groups as they become available.
Manager, Regulatory Affairs