Medical RAC Audits Reviewed by Statistician Frank Cohen Medical RAC Audits Reviewed by Statistician Frank Cohen

How To Show CMS Your Practice Actually Did CPIA

The language that CMS uses to describe Clinical Practice Improvement Activities (CPIA) is very vague, as pointed out in the article above. CMS is especially silent on what practices and providers must do to prove that they actually performed the CPIA measures they will claim to for the purposes of the Merit-based Incentive Payment System (MIPS) in 2017.

“The vague wording on each activity makes it open to interpretation, but I actually think this is a good thing,” says Michael Brohawn, FACMPE, practice administrator at Orthopaedics East & Sports Medicine Center in Greenville, NC. “It’s a good thing for practices because it’s more open-ended, and CMS has also said that they’re not going to issue any more guidance on CPIA this year.”

That choice may be deliberate on the part of CMS, to give practices latitude during 2017, a MIPS transition year, Brohawn says. The “wait-and-see” attitude could also give CMS a chance to observe how much effort is required for practices to implement various CPIA, so that the agency can write better guidance in future years.

Brohawn’s practice has applied to participate in Medicare’s Clinical Practice Improvement Activities Study, which will collect information from 42 provider organizations across the country to further assist the agency in issuing CPIA guidance.

One practice’s choices for CPIA

Brohawn’s practice will be implementing three CPIA measures in 2017:

  1. Collection and follow-up on patient experience and satisfaction data on beneficiary engagement, including development of improvement plan (high weight). Already in effect at Brohawn’s practice, which conducts quarterly patient surveys and makes changes to their workflow and patient service accordingly.
  2. Use of decision support and standardized treatment protocols (medium weight). Also already in use at Brohawn’s practice, where the physicians have created consensus protocols that are written down for each specific condition they treat, such as torn rotator cuffs. The protocol includes procedure type, tools, medication usage, and post-procedure therapy scheduling.
  3. Implementation of improvements that contribute to more timely communication of test results (medium weight). This CPIA measure would be new to Brohawn’s practice (see below).

The third measure, to improve timely communication of test results, hinges on the word “timely,” which CMS has not defined beyond simply that word itself, Brohawn says. “We plan to sit down with our staff and see what our baseline is for calling patients with test results,” he says. Eventually they will produce a report on how to improve their communication.

In case of audit, prove that you did CPIA

CMS has already shown that it doesn’t simply hand out incentive monies based on attestations alone. The agency continues to perform audits of attestations for its EHR Meaningful Use Incentive Program, and there’s no reason to think CMS won’t come up with a similar strategy for MIPS bonus payments, Brohawn believes.

To be clear, CMS has not yet announced any specific details for a MIPS auditing program, though officials have promised that there will be audits at some point. Information on future MIPS will be provided via additional rulemaking. “When that happens, it won’t be good not to be able to produce any evidence, even though CMS hasn’t said what will constitute evidence for CPIA,” Brohawn says.

His practice is taking a proactive approach. For each of the three CPIA measures described above, Brohawn has proof – copies of patient surveys, internal memos, and the final reports that explain what steps the providers and staff are taking to improve their practice.