If you are submitting MIPS for 2020, it might be a good time to consider getting the needed documentation in case you are randomly selected for a MIPS Data Validation and Audit. Due to the vast disruptions caused by COVID-19 and the day-to-day time constraints in a practice, we at Medical Advantage have prepared this overview relating to a MIPS Data Validation and Audit.
What is a MIPS Data Validation and Audit (DVA)?
Each year the Centers for Medicare & Medicaid Services (CMS) conducts data validation and audits (DVA) for the Merit-based Incentive Payment System (MIPS). This is the process of ensuring that the program operates with accurate and useful data. The DVA date for 2019 PY and 2020 PY is yet to be determined.
Which MIPS Categories or Measures are Subject to Data Validation and Audit?
The 2017 PY and 2018 PY DVA’s were conducted on approximately 40% of all available MIPS measures and activities. Of those 40% of measures available to be audited, the number of measures or activities selected for an actual DVA from each MIPS category will mirror each category weighting for that PY. For example, in 2018 approximately 50% of the total audits in a submission category were for Quality, 15% for IA and 25% for PI. Your specific DVA may require you to submit documentation related to at least one or all measures and activities you submitted for MIPS.
How Are Providers Chosen?
MIPS eligible clinicians are selected randomly for DVA. This random process will contain some manual input to ensure the sample selection is representative and inclusive of a variety of clinician types (urban, rural, large and small practices) and submission methods (EHR, QCDR, Claims, Registry etc.). You will be notified if selected for a MIPS data validation and audit and given an initial request of information with 45 days to respond to the request.
How Do I Prepare?
Since the DVA is performed at least 1-2 years after the PY, you may want to consider obtaining all needed documentation and screenshots now. This will ensure you have needed documents if you are selected for a random audit. You can make an electronic folder structure based on how you are doing your MIPS attestation either by individual provider or group. You can further break it down into the MIPS reporting categories. If you report MIPS for multiple years, make a separate file for each year.
How Do I Know What Documentation Will Be Needed?
In June of 2020, QPP released a zip file called the 2020 MIPS Data Validation Criteria. This file lists the 2020 criteria used to audit and validate data submitted in each of the Merit-based Incentive Payment (MIPS) performance categories. We found the excel file the most helpful to show the PI and IA validation materials. The quality section has its own zip file from the Quality Payment Program Resource Library. Select the appropriate zip file based on your quality collection type:
- 2020 Clinical Quality Measure Specifications and Supporting Documents
- 2020 Medicare Part B Claims Measure Specifications and Supporting Documents
- 2020 CMS Web Interface Measure Specifications and Supporting Documents
Need more help? Our experts at Medical Advantage can help with a MIPS data validation and audit, prepare your practice for a yearly MIPS audit, and provide advisory services for MIPS. If you would like to learn more about our services, please contact us.
Thank you to Shannon Kiffer for collaborating on this article.