tci Medicare Compliance & Reimbursement - 2019 Issue 9
Organize Your MIPS Files With this Audit Advice
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Article Overview
This article covers practical documentation and recordkeeping considerations for Merit-Based Incentive Payment System (MIPS) participation, with emphasis on audit preparedness, vendor coordination, and preserving supporting evidence across reporting categories. It is intended for clinicians, practices, and coding or quality reporting staff who manage MIPS submissions and need to understand the kinds of records and resources CMS may expect to see during review. The discussion focuses on general audit-file organization, documentation retention, and references to CMS and QPP guidance rather than on specific clinical measure selection.
Why This Topic Matters
MIPS participants may need to support reported data long after submission, so organizing records, screenshots, reports, and vendor-related documentation can help reduce audit risk and improve response readiness. The article is relevant to teams that rely on EHRs, registries, and other third-party intermediaries for quality and interoperability reporting.
Article Sections
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MIPS audit preparedness and documentation retention
Introduces the need to prepare for possible CMS audits and to maintain supporting records over extended reporting periods. It also touches on challenges related to changing technology and vendor dependence.
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Five steps to help back up your MIPS documentation
Summarizes a set of practical documentation categories to keep for reporting support. The section focuses on broad recordkeeping themes across quality, interoperability, and validation activities.
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Vendor matters
Explains the importance of keeping vendor interactions documented and recognizing the role of third-party intermediaries in MIPS reporting. It also notes that vendors may maintain their own records and can be subject to audit review.
What You Will Learn
- Why MIPS participants should keep audit-ready documentation
- What types of supporting records are commonly organized for reporting review
- How vendor-related documentation fits into MIPS recordkeeping
- Why CMS and QPP resources matter for validation and audit preparation
Who Should Read This
- Physicians and other MIPS-eligible clinicians
- Practice managers
- Quality reporting staff
- Compliance and audit support teams
- Coding and reimbursement professionals
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