A new CMS fact sheet on MIPS data submission provides basic information about MIPS reporting requirements and processes. The submission period to report 2017 MIPS data is open through March 31, 2018 (and for those reporting using the CMS Web Interface, the deadline to submit data is March 16, 2018).
MIPS participants can report data to CMS through a third party intermediary or directly via the QPP website. Providers who rely on vendors to submit data should confirm necessary next steps.
Here are some things to keep in mind if you're reporting your 2017 data directly using the new QPP data submission system:
- Verify EIDM credentials ASAP. The QPP submission system requires Enterprise Identity Data Management (EIDM) credentials to manage and submit data. Providers should make sure that information is correct as soon as possible. For more information on EIDM accounts and necessary roles under the QPP, review this EIDM user guide.
- Don't look for a "Save" button. There is no "submit" or "save" button in the QPP data submission portal. When you enter data, the system automatically updates your record, and once the submission period closes on March 31, CMS will calculate performance based on the data recorded in the system. It's unclear whether CMS will provide a final summary of your data after the submission period closes. We recommend providers take screenshots of the MIPS data submission portal once all data are entered.
- Prepare for MIPS Audits. CMS plans to conduct audits of MIPS data that will primarily focus on the Quality data category for the first year of the program. Before you complete MIPS data submission, we suggest that providers collect documentation to substantiate the data submitted across all performance categories. Use our 2017 MIPS Audit Checklist as a guide for the type of information you may want to have on hand.
Once you have completed 2017 MIPS data submission, be sure to make any necessary adjustments to your reporting strategy for the current program year (2018) requirements. You can check out our 2018 MACRA Final Rule Detailed Analysis presentation for those details.