MIPS 2017 and 2018 Data Validation Reviews to Begin in June 2019

Date: June 25, 2019

CMS announced last week that “Data Validation” reviews will begin in June, 2019, for the Merit-Based Incentive Payment System (MIPS) for Performance Years 2017 and 2018.  The “Performance Year” is the year a practice did the activities under MIPS and submitted data.  Performance Year is not the same as the Payment Year; for example, your payment year now (2019) is for services you “performed” in the first year of MIPS (2017).  Likewise, the 2018 “performance year” will be reflected in the 2020 “payment year”.

Data validation and review means that the actual data some practices submitted for performance years 2017 and 2018 will be reviewed for completeness; it is possible this might affect your MIPS bonus or penalty for these years.  In the 2017 MIPS Data Validation Fact Sheet, CMS notes:

By definition, data validation is the process of ensuring that a program operates on accurate and useful data … 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.

The contract to do these reviews was recently awarded to Guidehouse, a large consulting firm that does other government work similar to this.  You can link here and here to see two of the business announcements on the contract award; neither are to an “official” CMS webpage.  The notices are being sent by Guidehouse in June, 2019, via email or certified mail.  Importantly, you must comply with the request in full, and you cannot charge for the information if requested.  If you have concerns about the request, the CMS Quality Payment Program office can be reached by phone at 866.288.8292 or email to QPP@cms.hhs.gov.

The actual criteria Guidehouse will use, and a Fact Sheet for the corresponding year, are located in the QPP.CMS.gov “Resource Library”; the direct link to a ZIP file containing 6 files for 2017 and 9 files for 2018 is below.  (When you open a ZIP file, you will need to “click” the file that opens to get the contents of the file.)

  • Link here to a ZIP file for 2017 Data Validation information
  • Link here to a ZIP file for 2018 Data Validation information

We are happy to assist providers and groups in any way with MIPS, general claims issues as well as other coverage topics, which include proper code selection, chart reviews, and payer action questions.  We can also provide training on these or other subjects.  You can also download our “App”, Corcoran 24/7, which can be separately accessed via one of the links below.

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