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Data validation alert: MIPS audits start this month

Quick question: Where is the documentation that supports your doctor's merit-based incentive payment system (MIPS) performance in 2017?
If you don’t know the answer start looking now and you'll spare yourself a last-minute scramble. CMS has announced that data validation audits (DVA) for the first two years of MIPS participation will begin in July and practices that are contacted will have 45 days to submit their records.
“Responses including both the initial population and the follow-up requests for individual selections are required to be provided within 45 calendar days of the request,” the July 23 fact sheet states. "Once the information is received, we will review it and work with the MIPS participant to discuss any questions."
Guidehouse — the contractor that will conduct the DVA — will scrutinize how individual eligible clinicians, groups and virtual groups performed on three sections of MIPS in 2017 and 2018: quality, improvement activities and promoting interoperability (formerly known as advancing care information). Cost isn’t included in the audit.
The auditor may ask a practice to provide documentation for their claims on any or all of those sections of MIPS.
According to the fact sheet “MIPS participants will be selected randomly for DVA.” However, you should assume you’ll be audited if one or more eligible clinicians at your practice didn’t hit the requirements for quality measures. For example, the 2018 DVA fact sheet states:
If clinicians submitted six measures or less, less than the full measure set, or no outcomes/high priority measures were submitted, data documentation is required to validate whether you submitted all applicable MIPS measures and encounters using claims and registry data.
The DVA fact sheet for MIPS 2017 contains similar language.
While you’re watching for a documentation request from Guidehouse, review the MIPS validation criteria for 2017 and 2018. The links will take you to ZIP files that contain fact sheets and measure-specific data validation criteria for the sections under review.
Practices that are subjected to DAV will be able to submit the required documentation — which may include medical records — through a secure file-sharing platform or secure fax. And you can designate someone else to submit the information, such as office staff, your qualified registry or another contractor, the July 23 fact sheet states.
One final tip: Remind any staff who will be involved in responding to requests about HIPAA's minimum necessary rule. The rule states you must take steps to send the minimum amout of information that is necessary to accomplish the purpose of the request. That means you should not send a patient's entire medical record if an audit request is related to the treatment of a specific condition in 2018.
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