CMS audit requests

The Centers for Medicare & Medicaid Services (CMS) has contracted with Guidehouse to conduct data validation and audits of a select number of Merit-based Incentive Payment System (MIPS) eligible clinicians. MIPS eligible clinicians and groups are required by regulation to comply with data sharing requests, providing all data as requested by CMS.

If selected for data validation and/or audit, you will receive a request for information from Guidehouse sent via email or by certified mail. Please be on the lookout for this notification. You will have 45 days from the date of the notice to provide the requested information. If your practice receives a request and wants AQI to assist with data submission, email AskAQI@asahq.org as soon as possible.

If your practice does not provide the requested information, CMS may take further action, including the possibility that you will be selected for future audits.

2019 registration deadlines approaching

ASA members who will be participating in 2019 NACOR Quality Reporting must complete their 2019 ASA membership renewal by the end of business on Tuesday, October 1, 2019. Members who have not renewed their memberships by October 1 will be charged the NACOR non-member rates for 2019 quality reporting."

2018 MIPS Targeted Review deadline September 30

Eligible clinicians (ECs) and groups who believe an error was made in their 2018 MIPS scores may request a targeted review by CMS. The deadline to submit a targeted review is September 30, 2019, and CMS may request practices submit additional documentation to support their appeal.

ECs and groups can request a targeted review by visiting the Quality Payment Program (QPP) website and logging in with HARP credentials. For more information about how to request a targeted review, review the 2018 Targeted Review Fact Sheet (PDF) and the 2018 Targeted Review FAQs (PDF).

RESOURCES

2019 Resources

2019 NACOR registration

2019 Policies and Procedures

2019 Individual Quality Reporting consent form

2019 NACOR pricing (PDF)

2019 QCDR Measure Specifications (PDF)

2019 Recommended Improvement Activities

NACOR Data Definitions

NACOR News Library

Read past issues of AQI's NACOR News.

Office Hours FAQs

Question: If a provider has left the practice half way through the year - does the practice need to report the provider's cases?

If the practice is reporting as a group and the provider performed cases in 2018, the practice needs to be reporting 60% of all eligible cases for that provider regardless if they are still at the practice or not as CMS is evaluating the data at the TIN level not the individual NPI. If the practice is individually reporting, the data will follow the provider's NPI.

Question: In regards to the reporting year on the AQI website it state to submit 60% of eligible cases and we understand it is not pick your pace but does this mean 60% of 2018 cases? Can you elaborate?

The 2018 MIPS reporting requirement is to report on 60% of the denominator eligible cases for 6 measures including 1 outcome measure for the 12 month reporting period (1/1/2018 - 12/31/18). For example, If your practice is reporting MIPS 76 - Prevention of Central Venous Catheter (CVC - Related Bloodstream Infections and places 75 central lines during 2018 your practice would need to report on 45 cases which is 60% of the eligible cases.

Question: Is it possible for all providers in a practice to be non-MIPS eligible and not required to submit data as individuals, but are eligible as a group?

Yes if the individual providers do not meet the 2018 MIPS participation criteria (billed $90,000 or less in Physician Fee Schedule (PFS) services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare secondary Payer) and have 200 or fewer Medicare Part B FFS beneficiaries) the practice can be MIPS eligible as a group if the group has billed $90,000 or more in PFS services furnished to Medicare Part B beneficiaries and have 200 or more Medicare Part B beneficiaries.