Physician Practice

Dutifully document improvement activities during inaugural year of MIPS or risk payments

Physician Practice Insider, June 12, 2017

Take a close look at the documentation guidelines that CMS suggests for the practice improvement portion of the merit-based incentive payment system (MIPS) and you may ward off future audits and avoid having to forfeit revenue.

For the 2017 reporting year, MIPS-eligible providers are required to attest — in a simple “yes/no” format — to as many as four improvement activities, formerly known as clinical practice improvement activities (CPIAs), to receive the most available points under this slice of MIPS, which makes up 15% of a provider’s total quality-reporting score.

While the attestation may demand only a brief response, the documentation that you’re required to keep as proof of your work comes with more strings attached, and you should hew closely to CMS recommendations.

“It is absolutely critical that groups begin to create good habits that will set them up for long-term success,” advises Brandon Richardson, lead MIPS consultant with Medical Information Software Technology (MIST) in Post Falls, Idaho.

Similar to meaningful use reporting, providers may face an audit in future years related to their improvement-activity attestation, and the quality of your documentation will be the only thing standing between keeping your MIPS bonus money or having to return it to the feds. Let that thought guide your actions this year, suggests Richardson.

“Document with the assumption that you will be audited,” he says.

You can find the documentation standards on the Quality Payment Program website. Navigate to the “Resources and Education” page — https://qpp.cms.gov/resources/education — and download the “MIPS Data Validation Criteria” file. In that folder, you’ll find a spreadsheet and PDF of the suggested guidelines. 

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