Thursday, August 30, 2018 | Cherie Kelly-Aduli
In Year 3 of the Quality Payment Program (QPP) clinicians have 7% of their Medicare Part B reimbursement at risk for non-participation in the MIPS program. With that being said, providers can score a perfect 100 and still have their positive payments adjusted negatively if they are unable to provide proof of their work. Unfortunately, there has not been much published by CMS on exactly what is required in the event of a MIPS audit. Below is a list of recommended screenshots to help you organize your documentation.
NPI Lookup Tool
First you will want to see if your provider is considered a MIPS eligible clinician by going to the NPI look up tool located here. Keep in mind that if you work under multiple tax IDs you may be exempt from one but still meet the minimum threshold under another tax ID. If you are exempt you will want to take a screenshot stating that you are not required to participate in the MIPS program.
For Meaningful Use audits providers were required to have a letter from their EHR vendor verifying that they were using CEHRT for the time period in which they attested in addition to providing proof of payments to the EHR vendor. This may sound like overkill for MIPS but I think you should probably have this as part of your file in the event that you are audited.
Quality Measures Documentation
Data validation will occur for claims and registry measures if a provider or group does not submit the correct amount or type of measures required under MIPS. This process is very similar to MAV (Measures Applicability Validation) for PQRS.
Promoting Interoperability Documentation (aka the Advancing Care Category)
Improvement Activities (IA) Documentation
CMS can request any of your MIPS records or data for up to six (6) years after the program year in which you attested. Knowing this you will want to have your documentation in both hard and electronic copies for at least 10 years. Once you receive your initial letter from CMS stating that you have been selected for an audit you will have 10 days to respond to their letter. The maintenance of your data is critical to your overall success in the MIPS program. Reach out to MedAxiom if you need further assistance in preparing you documentation for an audit.
Illustration: Lee Sauer
Cherie Kelly-Aduli is the CEO of QPP Consulting Group in Mandeville, Louisiana, and a MedAxiom consultant. She has over 16 years of experience in healthcare operations, population health and accountable care. Prior to opening her own firm, Cherie was the Director of Clinical Operations and subsequently Director of Population Health and Accountable Care for the Louisiana Heart Hospital and Medical Group located in Lacombe, Louisiana.
Throughout her career Cherie has been highly successful in efficient practice management, practice adoption of electronic health records, and assisting providers with exceeding standards for patient satisfaction. As payors and patients have transitioned to "pay for value," Cherie has been instrumental in leading private practices and hospital systems to achieve high quality outcomes under the Meaningful Use, PQRS and Value Based Modifier programs; she is now assisting groups with their adoption of the Merit Based Incentive Payment system under MACRA.
To contact, email: email@example.com