Accurate MIPS (Merit-Based Incentive Payment System) reporting is essential for avoiding negative Medicare payment adjustments and ensuring compliance with CMS standards. However, many practices make avoidable mistakes that impact their performance scores. This article outlines the most common MIPS reporting pitfalls and provides strategies to prevent them.
Reporting errors can result in:
Lower MIPS scores
Reduced or lost incentive payments
Increased risk of CMS audits
Missed opportunities to highlight care quality and performance
Understanding these pitfalls in advance helps billing teams and providers safeguard their reporting process and maintain compliance.
Selecting Inappropriate Measures
Choosing measures that do not align with the provider’s specialty or patient volume can lead to incomplete data or unreportable results.
Avoid It: Review CMS's recommended specialty measure sets and historical performance data before finalizing selections.
Inaccurate or Incomplete Coding
Incorrect CPT, HCPCS, or ICD-10 codes tied to quality measures can result in failed data validation.
Avoid It: Regularly update code libraries and cross-check documentation with coding requirements for each measure.
Failing to Meet Data Completeness Criteria
CMS requires that data be submitted for a minimum percentage of eligible patients for each measure.
Avoid It: Track patient counts and ensure reporting thresholds are being met throughout the year—not just at year-end.
Late or Missed Submissions
Missing CMS deadlines can lead to automatic penalties.
Avoid It: Maintain a reporting calendar and assign specific staff members to monitor and confirm timely submissions.
Lack of Documentation to Support Reported Data
Submitting data without proper clinical documentation can raise red flags during audits.
Avoid It: Align billing data with provider documentation and store records securely for audit readiness.
Ignoring MIPS Category Weight Changes
Each year, CMS may adjust the weights of the MIPS performance categories (Quality, Cost, Improvement Activities, and Promoting Interoperability).
Avoid It: Review annual CMS Final Rules to understand how score calculations may shift and how to adjust your focus accordingly.
Underutilizing EHR Capabilities
Many practices fail to leverage their electronic health record systems to automate MIPS tracking and reporting.
Avoid It: Work with your EHR vendor or IT team to set up automated reporting tools, dashboards, and alerts for MIPS data.
Conduct periodic internal audits throughout the year
Schedule measure reviews with billing and clinical teams
Use certified registries or QCDRs to simplify submission
Attend CMS webinars and subscribe to official MIPS updates
Designate a MIPS point of contact in your organization
Avoiding common MIPS reporting pitfalls requires careful planning, attention to detail, and regular team communication. By staying informed and proactive, billing and administrative staff can help protect their organization’s revenue, meet compliance standards, and ensure accurate representation of performance.