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Mid-Week MACRA Minute – Data Validation & Auditing

Helping you put the MIPS pieces together each week!

MIPS Data Validation and Auditing

CMS is required by the Quality Payment Program Final Rule with comment, to provide the criteria they will use to audit and validate measures and activities for the 2017 transition year of MIPS for all performance categories: Quality, Advancing Care Information and Improvement Activities.

According to CMS, data validation is the process of ensuring that a program operates on accurate and useful data. MIPS requires all-payer data for all data submission mechanisms with the exception of claims and the CMS Web Interface. The data from payers, other than Medicare, will be used for informational purposes to improve future validation efforts and will not be the only source of data used to make final determinations on whether you pass or fail an audit in the transition year.

Data validation for MIPS will be conducted annually by CMS. Providers could also receive an audit request from CMS that will require an initial response within 10 business days.

How long should I retain documentation?

Providers are encouraged to keep documentation up to 10 years and CMS may request any records or data retained for the purposes of MIPS for up to 6 years. This information is documented in the final rule and in accordance with the False Claims Act.

  • Quality – For the transition year, CMS’ data validation process for the Quality performance category will apply for claims and registry submissions to validate whether you submitted all applicable measures when submitting fewer than six measures or when you do not submit the required outcome measure or other high priority measure, or submit less than the full set of measures in the applicable specialty set.
  • Advancing Care Information – You should retain documentation to support the submission for the Advancing Care Information performance category.
  • Improvement Activities – Your documentation used to validate your activities should demonstrate consistent and meaningful engagement within the period for which you attested.

For more details regarding Data Validation & Auditing from CMS visit the resource library at or visit the MediSYS website at

Question? The Quality Payment Program Service Center can be reached at 1-866-288-8292 (TTY 1-877-715- 6222), Monday through Friday, 8:00 AM-8:00 PM Eastern Time or via email at [email protected].


Contact us to find out more about MediSYS at [email protected] or 205-631-5969.