audit readiness for mips · meaningful use measures for each applicable program year to attempt...
TRANSCRIPT
Audit Readiness for MIPS
13 minutes
October 2, 2018
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Lake Superior Quality Innovation Network (LSQIN)
Three quality improvement organizations:• MPRO in Michigan
• Stratis Health in Minnesota
• MetaStar in Wisconsin
Collaboration to improve health care for Medicare consumers, share best practices, and maximize efficiencies
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Disclaimer
Information provided in this presentation is based on the latest information made available by the Centers for Medicare & Medicaid Services (CMS) and is subject to change.
CMS policies change, so we encourage you to review specific statutes and regulations that may apply to you for interpretation and updates.
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Objectives
• Historical Perspective on Meaningful Use (MU) CMS Audit Program
• The Basics of Audit Readiness
• Review CMS Data Validation and Audit Requirements for Merit-based Incentive Payment System (MIPS)
• Review Excel Audit Readiness and Data Validation Tool
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Historical Perspective
• Audits do happen
• MU participants had an approximate one in 10 chance of being audited
• Auditors did retract incentive funds on behalf of CMS when program participants failed the audit.
• Number one audit flag and reason for payment retraction:
― poorly done or no Security Risk Assessment for the Protect Patient Health Information objective
• Biggest risk: not being prepared for an audit
• Prior MU program required two week response time to audit materials request
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Historical Perspective
• Six year retention period required for MU attestation documentation
• Audits under MU were performed by a contracted company (Figliozzi & Co.)
• Following two slides are excerpts from CMS guidance document on MU audit program
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Historical Perspective
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Historical Perspective
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The Basics of Audit Readiness
• Audits are in the news and have our attention
• June 12, 2017 article in ‘Fierce Healthcare’ online:”Audit estimates CMS issued hundreds of millions of dollars worth of incorrect EHR incentives”
• Detailed Office of Inspector General (OIG) PDF at:https://oig.hhs.gov/oas/reports/region5/51400047.pdf
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Main Points in OIG Report
• “On the basis of our sample results, we estimated that CMS inappropriately paid $729,424,395 in incentive payments to EPs who did not meet meaningful use requirements. These errors occurred because sampled EPs [Eligible Providers] did not maintain support for their attestations. Furthermore, CMS conducted minimal documentation reviews of self-attestations, leaving the electronic health record [EHR] program vulnerable to abuse and misuse of Federal funds”
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OIG recommends that CMS…
• review EP incentive payments to determine which EPs did not meet meaningful use measures for each applicable program year to attempt recovery of the $729,424,395 in estimated inappropriate incentive payments,
• review a random sample of EPs’ documentation supporting their self-attestations to identify inappropriate incentive payments that may have been made after the audit period,
• educate EPs on proper documentation requirements,
• Finally, as CMS implements MACRA, we recommend that any modifications to the EHR meaningful use requirements include stronger program integrity safeguards that allow for more consistent verification of the reporting of required measures so that CMS can ensure that EPs are using EHR technology consistent with CMS’s goal of Advancing Care Information under MIPS.
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The Basics of Audit Readiness
• Additional call by two senators on July 12 for follow up on improper $730M payments (Letter to CMS Administrator from Senators Hatch and Grassley)
“If CMS is capable of recovering taxpayer money that should have not have been spent, the agency should take all reasonable steps to do so,” the Senators wrote.
Source: Healthcare IT News: http://tinyurl.com/y8st79c2
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Senators Foreshadow MIPS Auditing
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Which Categories MIPS May be Audited
CMS has suppled a ‘Data Validation’ Excel tool for these three categories within MIPS. The CMS guidance is incorporated into the Lake Superior QIN Excel tool as well.
Promoting Interoperability
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CMS Data Validation and Audit Fact Sheet
• CMS has provided a Data Validation and Audit Fact Sheethttps://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2018-MIPS-Data-Validation-Criteria.zip
• CMS requires a six year retention period for MIPS and Federal False Claims Act encourages up to 10 years
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CMS Data Validation and Audit Fact Sheet
• The Data Validation and Audit Fact Sheet is only four pages and does not provide detailed guidance
• At the bottom of page one, CMS states:“Under MIPS, CMS will conduct an annual data validation and audit process. If selected for a data validation or audit, you will have 45 calendar days to complete data sharing as requested or an alternate timeframe that is agreed upon by CMS and the MIPS eligible clinician or group.”
• CMS will ‘validate’ the data you submit and may also conduct an audit. These are two separate and distinct activities.
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Audit Readiness Excel Tool
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Audit Readiness Excel Tool
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Your Audit Readiness Files
• Best approach is an electronic set of files/folder for quick response to CMS
• Prior submissions to the CMS contracted auditor were done primarily via secure web portal (uploads)
• Organize at the Taxpayer Identification Number (TIN) level as that is how the program is organized and audit info will be requested
• Base your electronic folder structure on how you are attesting (by individual provider or by a group) and break down further into MIPS reporting categories.
• Create a year by year file structure
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Lake Superior QIN Contacts
Please submit any questions to your state Lake Superior QIN QPP Help desk at:
MI: Holly Standart (248) [email protected]
MN: Candy Hanson (952) 853-8524
WI: Mona Mathews (800) 362-2320
This material was prepared by the Lake Superior QualityInnovation Network, under contract with the Centers forMedicare & Medicaid Services (CMS), an agency of theU.S. Department of Health and Human Services. Thematerials do not necessarily reflect CMS policy.
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