One sign that MIPS really is the future of provider payments: CMS plans to audit provider performance and that includes completion of clinical practice improvement activities.
And now CMS has released
MIPS data validation criteria to help providers document improvement activities. It's a ZIP file that contains a number of documents including an Excel file of improvement activities that you can quickly sort and filter.
The last column lists suggested documentation for each activity. For example, a provider may document the implementation of medication management practice improvements in four ways:
- Documented medication reviews or reconciliation -- patient medical records demonstrating periodic structured medication reviews or reconciliation; or
- Integrated pharmacist -- evidence of pharmacist integrated into care team; or
- Reconciliation across transitions -- reconciliation and coordination of mediations across transitions of care; or
- Medication management improvement plan -- report detailing medication management practice improvement plan and outcomes, if available.
Practices will need to hang on to the documentation, according to a fact sheet included in the file.
CMS may request any records or data retained for the purposes of MIPS for up to six years.
In addition, CMS states that providers are "encouraged" to keep documentation for at least 10 years, in accordance with the False Claims Act.