Since I have been involved in hundreds of audits and appeals related to the CMS EHR Incentive programs it should be no surprise I have an interest in what the Proposed Rule says about audits relative to the MIPS process. Here are a few clarifying comments from CMS that were included in the Proposed Rule:
Will there be audits? Yes, the Proposed Rule outlines a process to “selectively audit MIPS eligible clinicians on a yearly basis”.
What types of documentation will be needed to respond to an audit? According to the Proposed Rule you can expect to “Provide substantive, primary source documents as requested. These documents may include: Copies of claims, medical records for applicable patients, or other resources used in the data calculations for MIPS measures, objectives and activities.”
What happens if data cannot be verified during the audit? “If a MIPS eligible clinician or group is found to have submitted inaccurate data for MIPS, we propose that we would reopen, revise, and recoup any resulting overpayments “.
Will there be any auditing against any entity besides MIPS eligible clinicians? You bet, “any third party intermediary (that is, a QCDR, health IT vendor, qualified registry, or CMS-approved survey vendor) must comply with certain auditing requirements as a condition of their qualification or approval to participate in MIPS as a third party intermediary.”...”Further, we propose the entity must retain all data submitted to CMS for MIPS for a minimum of 10 years.”
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