With gathering the data and preparing submissions for MIPS reporting for the 2018 Quality Payment Program, practices need to document their submissions and supporting records in case of a CMS or ONC audit. The Quality Reporting Engagement Group has created a checklist to help those practices keep track of what they need for MIPS reporting.
is a helpful overview and will assist a practice in being prepared in the event of an audit.
According to a recent presentation held by CMS, the presenter noted: “… providers should retain copies of medical records, charts, reports, and any electronic data utilized, to determine which measures and activities were applicable and appropriate for their scope of practice, and patient population for reporting under MIPS for up to 10 years after the conclusion of the performance period, to prepare for verification in the event that you're selected for an audit."
“This record-retention timeframe aligns with the record-retention timeframes already in place for APMs, either established in regulation or included in participation agreements. CMS may request any records or data retained for the purposes of MIPS for up to six years and three months. And we will provide audit specifications through subreg guidance. MIPS-eligible clinicians or groups selected for data validation audits will be provided instructions and examples of documents required.1
The Quality Reporting Engagement Group has successfully completed 125 audits under previous CMS reporting and attestations. For help in your practice, contact firstname.lastname@example.org
or call 877-570-8721 x2.
- Merit-Based Incentive Payment System (MIPS) Overview: Understanding Advancing Care Information (ACI) & Improvement Activities; CMS Presentation, December 13, 2017, https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-transcript.pdf