Starting today, August 3, 2020, CMS is resuming suspended medical reviews as well as initiating new audits. While this should merely be a return to business as usual for MIPS providers, it is important to note that this resumption of CMS audits will now continue regardless of the status of the current public health emergency. To help our readers get ready, we thought this would be a good time to offer a quick refresher on preparing for and surviving a MIPS audit.
For reference, check out our new eBook Winning the Game: Surviving a MIPS Audit.
As with most things, it is always better to be prepared for an audit so that you and your staff are not scrambling to respond when and if one occurs. To prepare for a potential audit, we recommend performing the following actions:
- Retain timestamped copies of full-page screenshots that display successful registrations and submissions, as well as any pertinent communications with CMS.
- Retain documents demonstrating that your performance was valid and includes both numerators and denominators of the EHR measure data that was submitted to CMS for MIPS attestation.
- Most documentation will be in form of screen shots of your EHR that include Date/Time
- Be sure documentation contains all necessary details, including NPIs, CMS certification number, clinical name and practice name.
- Generate quality measure reports monthly and use these to track progress.
- Run a random sample validation test of 5-10 patients per quality measure at least once a month.
- Complete an annual Security Risk Assessment (SRA) with all documentation requirements, such as initial assessment, identification of gaps for improvement and documentation of efforts to correct any deficiencies.
- Document all policies and procedures throughout the year and validate them with two dated signatures.
- Create a specific file to store all MIPS documentation and evidence for each year.
Follow the Guide
When it comes to MIPS audits, the CMS website is always the best guide to follow. You can find the resources you need by performing the following steps:
- Go to the QPP webpage and scroll down until you reach the search bar
- Search for “Audit”
- Download the MIPS Data Validation Criteria for the correct year
To avoid incurring penalties, be aware that the following deadlines should be adhered to when and if an audit letter is received:
- Initial requests for information are sent in June or July each year
- 45 days from the date of the letter being written, a response must be made
- As needed, evaluations may continue through December of that year
Appealing a Failed Audit
What are you supposed to do when you fail an audit? First of all, do not panic. If you have prepared and have proper documentation, you can always appeal the decision by using one of the following appeal types:
- Failed Audit Appeal – Allows provider to demonstrate MIPS by addressing each failed measure on audit. Appeals of this type must be filed within 30 days after receipt of the adverse audit determination letter.
- Failed Reporting Appeal – Allows provider to show that CEHRT was used to successfully demonstrate MIPS but failed due to a reporting issue. Appeals must be filed within 30 days after the attestation deadline.
- CQM e-Reporting Appeal – Allows provider to show that CQM e-reporting was successful in meeting MIPS. Appeals must be filed within 30 days after the attestation deadline.
- Eligibility Appeal – Allows an eligible provider to show that all EHR Incentive Program requirements were met and that the provider should have been able to register and attest for the Program but could not due to circumstances outside the provider’s control. For example, being unable to register by the deadline. Appeals must be filed within 30 days after the attestation deadline.
Does your practice need assistance with MIPS attestation? Are you getting the most out of your reimbursements? To find out about all the services and solutions Nextech can provide to ensure regulatory success for your practice, fill out this form and a member of our team will be in touch soon.