Medicare Compliance & Reimbursement

Tip: Auto-population often leads to inaccuracy — and audit.

Merit-Based Incentive Payment System (MIPS) measures that don’t meet threshold requirements followed up by lackluster supporting documentation are risky actions and may cause you to fail a MIPS audit. However, some practices skirt the rules to boost their chances of an incentive — and that’s fraud.

“Overall, CMS is looking for instances of fraud, waste, and abuse of this system,” warns Lora Woltz, ONC HIT certification manager in the Eye Care Leaders April 25 webinar, “Bulletproofing the MIPS Audit File.”

“If they suspect it, they will escalate the audit into an investigation status,” Woltz explains. “You can help avoid this by not engaging in high-risk behaviors.”

There are five specific things Woltz cautions MIPS providers to watch out for. Review these questions to see if you’re pushing the limits:

• Are you “cloning” patient data by cutting and pasting in your EHR from one visit to the next? “If you undergo a medical record audit, cloning is going to be one of the primary sources of their investigation,” Woltz says.
• Do clinicians identify themselves and take »ownership of their inputs when adding notes to an EHR record? “If there’s not a clear way to track who did what, then that can cause a problem for you if you undergo an audit,” maintains Woltz.
• Are you overusing the auto-populate option of your EHR? “This action runs parallel to data cloning, so it’s allowed but data should still be checked and confirmed,” she reminds.
• Do you add or alter dates after the fact? Date of service changes are going to draw attention to your audit log, intentional or otherwise, indicates Woltz.
• Are you lying about measures, codes, or more to increase payments? Patient fabrication and upcoding are on the “darker end of the spectrum,” and auditors will home in on these malicious EHR actions, she warns.