MIPS Data Validation and Auditing
The Quality Payment Program Final Rule with comment requires CMS to provide the criteria it will use to audit and validate measures and activities for the 2017 transition year of MIPS for the Quality, Advancing Care Information, and Improvement Activities performance categories.
By definition, data validation is the process of ensuring that a program operates on accurate and useful data. MIPS requires all-payer data for all data submission mechanisms with the exception of claims and the CMS Web Interface. The data from payers other than Medicare will be used for informational purposes to improve future validation efforts and will not be the only source of data used to make final determinations on whether you pass or fail an audit from the 2017 transition year.
Under MIPS, CMS will conduct an annual data validation and audit process.
How long should I retain documentation?
In accordance with the False Claims Act, you should keep documentation up to 6 years and, as finalized in the 2018 MIPS Year 2 final rule, CMS may request any records or data retained for the purposes of MIPS for up to 6 years.
The Quality performance category within MIPS assesses health process and outcomes through quality measures.
MIPS eligible clinicians should demonstrate quality performance assessed against a performance benchmark. The performance benchmark is based on historical or performance period data (or potentially based on 2017 performance data for quality measures with no historic benchmark).
For the 2017 transition year, CMS’ data validation process for the Quality performance category will apply for claims, EHR, and registry submissions to validate whether you submitted all applicable measures and encounters when submitting fewer than six measures or when you do not submit the required outcome measure or other high priority measure, or submit less than the full set of measures in the applicable specialty set.
Advancing Care Information
The MIPS Advancing Care Information performance category replaces the Medicare EHR Incentive Program for eligible professionals, also known as Meaningful Use. The MIPS Advancing Care Information performance category promotes patient engagement and the electronic exchange of information using certified EHR technology. Under this performance category, eligible clinicians will have greater flexibility in choosing measures to report.
You should retain documentation to support submissions for the Advancing Care Information performance category.
- ACI Data Validation Criteria (EHR Technology Certified to the 2015 Edition)
- ACI Transitional Year Validation Criteria (EHR Technology Certified to the 2014 Edition)
The MIPS Improvement Activities performance category assesses how much you participate in activities that make clinical practice better. Examples include:
- Activities related to ongoing care coordination
- Clinician and patient shared decision making
- Regular use of patient safety practices
- Expanding practice access
Under this performance category, you’ll be able to choose from many activities to show your performance. This performance category also includes incentives to help you participate in certified patient-centered medical homes and APMs.
Your documentation used to validate your activities should demonstrate consistent and meaningful engagement within the period for which you attested.