Audit Readiness for Merit-Based Incentive Payment System (MIPS)

Transcription

1 Audit Readiness for Merit-Based Incentive Payment System (MIPS) 13 minutes September 19, 2017 Lake Superior Quality Innovation Network (Lake Superior QIN) 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 1

2 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. 2 Objectives Historical Perspective on Meaningful Use (MU) CMS Audit Program The Basics of Audit Readiness Review CMS Data Validation and Audit Requirements for MIPS Review Excel Audit Readiness and Data Validation Tool 3

3 Historical Perspective Audits do happen, MU participants had an approximate 1 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 incentive payments 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 4 Historical Perspective Six year retention period required for Meaningful Use attestation documentation Audits under MU were performed by a contracted company (Figliozzi & Co.) Following two slides are excerpts from CMS guidance document on Meaningful Use audit program 5

4 Historical Perspective Source: 6 Historical Perspective Source: 7

5 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: pdf 8 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 did not maintain support for their attestations. Furthermore, CMS conducted minimal documentation reviews of self-attestations, leaving the EHR program vulnerable to abuse and misuse of Federal funds Source: 9

6 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 selfattestations to identify inappropriate incentive payments that may have been made after the audit period, educate EPs on proper documentation requirements, Finally, as CMS implements Medicare Access and CHIP Reauthorization Act (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. 10 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: 11

7 Senators foreshadow MIPS auditing 12 Which Categories MIPS may be audited No CMS guidance as of yet. Relying on Physician Quality Reporting System (PQRS) and MU previous information CMS has supplied Data Validation Excel tool for Improvement Activities (IA) No CMS guidance as of yet. Relying on previous MU information Source: CMS Quality Payment Program Train-The-Trainer 13

8 CMS Data Validation & Audit Fact Sheet CMS has provided a Data Validation and Audit Fact Sheet CMS requires a six year retention period for MIPS and Federal False Claims Act encourages up to 10 years 14 CMS Data Validation & Audit Fact Sheet The Data Validation & Audit Fact Sheet is only three pages and does not provide detailed guidance At the bottom of page 1, CMS states: Under MIPS, CMS will conduct an annual data validation process. Additionally, you could receive a request from CMS for an audit, which requires an initial response within 10 business days. CMS will validate the data your submit and may also conduct an audit. Two separate and distinct activities 15

9 Audit Readiness Excel Tool 16 Audit Readiness Excel Tool 17

10 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 Tax 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 18 Lake Superior QIN Contacts Please submit any questions to your state LSQIN QPP Help desk at: MI: Holly Standhardt (248) MIQPPHelp@mpro.org MN: Candy Hanson (952) QPPHelp@stratishealth.org WI: Mona Mathews (800) QPP@metastar.com 19

11 This material was prepared by the Lake Superior Quality Innovation Network, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The materials do not necessarily reflect CMS policy. 11SOW-MI/MN/WI-D