MIPS Audit Services for Physician Practices
MIPS audits started in June 2019 and will continue throughout the duration of the program. MIPS has significant audit vulnerabilities in each of its four performance categories: Quality, Promoting Interoperability, Cost, and Improvement Activities. The internal, confidential audit, will focus on known compliance issues for each category. The audit will also identify opportunities for improved performance in the MIPS, based on documentation and a detailed understanding of the requirements at a granular level.
HCIT Consulting can provide a one time audit or provide monthly audit subscription services performed by our Physician Coding Expert, Dr. Michael Marron-Stearns.
- Quality Performance Category: The audit team will review a representative sample of encounters that meet or do not meet the performance requirements for the subset of quality measures being reporting by the practice. This includes a review of the documentation needed to support individual measure specific denominator eligibility, numerator eligibility, and applicable exclusions and exemptions. It will also explore the practices existing quality measure strategy and offer guidance on additional measures that the practice may wish to consider reporting to increase performance.
- Promoting Interoperability Category: CMS conducted an “overhaul” of this category for 2019 and future years, making it much more difficult to attain high scores. The risk of a negative audit has also increased significantly. The audit team will review eligible encounters and supporting documentation tied to reporting performance in this category, including but not limited to, specific requirements for the Health Information Exchange and Provide Patient Access Measures, which together make of 80% of the points in this category.
- Cost Category: The weighting of this category is increasing from 15% in 2019 to 30% in 2022, making performance in this category paramount to achieving a high MIPS score. Scores in this category are determined by observed versus risk-adjusted expected costs for Medicare patients for certain specified cost measures attributed to the practice. CMS will determine performance based on risk-adjusted episode costs, using a method very similar to the risk adjustment model used by Medicare Advantage. The audit team will focus on missing or underspecified documentation relevant to HCC coding and risk adjustment.
- Improvement Activities Category: Reporting for this category has been limited to attestation, however, the specifications provided for each improvement activity are readily subject to interpretation. CMS has provided auditors with documentation requirements for a majority of the improvement activity measures. Auditors will review current documentation to ensure it is consistent with CMS requirements for the reported improvement activities.
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