In June, the Centers for Medicare & Medicaid Services (CMS) announced the commencement of audits for the Merit-based Incentive Payment System (MIPS). The contract was awarded to Guidehouse, formerly known as the US Public Sector of PricewaterhouseCoopers. Guidehouse is transmitting notifications of audits via email or certified mail. The auditors require the requested information be provided within 45 calendar days.
CMS has issued guidance about the requirements to fulfill the audit. For example, the 2017 “Provide Patients Access” criteria, which was a component of the Advancing Care Information category requires: “Dated report, screenshot, or other information that documents the number of times a patient or patient authorized representative is given access to view, download, or transmit their health information. This could include instructions provided to the patient on how to access their health information including the website address they must visit, the patient's unique and registered username or password, and a record of the patient logging on to show that the patient can use any application of their choice to access the information and meet the API technical specifications.”
The guidance about the audit requirements, which can be accessed in the Quality Payment Program’s online resource library, are titled: “MIPS Data Validation Criteria.” The 2017 and 2018 versions have been posted here. CMS advises that documentation about the Merit-based Incentive Payment System should be maintained for six years. It’s an opportune time to review this newly released guidance to ensure your documentation strategy for program compliance is responsive to the new guidelines. Should you be audited, you’ll be ready.
Elizabeth Woodcock is the founder and principal of Woodcock & Associates. She has focused on medical practice operations and revenue cycle management for more than 25 years. She has led educational sessions for a multitude of national professional associations and specialty societies, and consulted for clients as diverse as a solo orthopaedic surgeon in rural Georgia to the Mayo Clinic. She is author or co-author of 17 best-selling practice management books, to include Mastering Patient Flow and The Physician Billing Process: Avoiding Potholes in the Road to Getting Paid. Elizabeth is a Fellow in the American College of Medical Practice Executives and a Certified Professional Coder. In addition to a Bachelor of Arts from Duke University, she completed a Master of Business Administration in healthcare management from The Wharton School of Business of the University of Pennsylvania. She is currently a doctoral student at the Bloomberg School of Public Health of Johns Hopkins University.
The contents of The Sentinel are intended for educational/informational purposes only and do not constitute legal advice. Policyholders are urged to consult with their personal attorney for legal advice, as specific legal requirements may vary from state to state and/or change over time.
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