MIPS audits are not rare. They are expected.

Every year, the Centers for Medicare & Medicaid Services (CMS) audits a portion of participants to verify the accuracy of their MIPS submissions. These reviews can happen as soon as two weeks after submission or up to six years later. That means the documentation you create in 2025 must still hold up in 2028.

For providers and EHR vendors, audit readiness is not optional. It determines whether your MIPS score stands firm or falls apart under review.

Why Audit Readiness Matters

MIPS reporting has become more precise, and CMS is increasing oversight. Each submission must not only reflect correct data but also be supported by verifiable documentation. If your submission is audited and you cannot provide evidence, CMS may reduce or revoke your score, which directly affects your reimbursement.

The good news is that audits do not have to be stressful if you prepare in advance.

Audit readiness gives you three major advantages:

Protection against financial penalties. Missing proof can cost thousands in adjustments.
Confidence in compliance. Documentation becomes a living record, not a scramble after submission.
Operational efficiency. Teams spend less time rebuilding reports when everything is tracked and verified along the way.

Who Needs to Care

Audit readiness is critical for anyone involved in MIPS reporting:

Providers and group practices participating in traditional MIPS or MVPs.
EHR vendors and registries responsible for data collection, validation, and submission.
Administrative and compliance teams managing attestation, PI reporting, or quality tracking.

If you touch MIPS data in any form, from measure tracking to file submission, you play a role in audit readiness.

What CMS Looks for in an Audit

CMS auditors evaluate three key elements:

Accuracy: Does the documentation match the submission?
Completeness: Are all required elements included?
Traceability: Can the data source and submission be verified?

To meet these expectations, every organization should maintain a structured Book of Evidence. It is the single most effective way to keep your MIPS documentation audit-ready.

How to Build Your MIPS Book of Evidence

Think of your Book of Evidence as your compliance binder, digital or physical, that holds all proof of MIPS activities and submissions. Start building it now for the 2025 performance year and continue updating it as you go. Do not wait until submission.

Here is a list of 10 things you must have ready in event of a MIPS audit,based on CMS guidelines and best practices:

1. PDMP Review Documentation
Proof with patient name and date showing that at least one Prescription Drug Monitoring Program (PDMP) review was completed before prescribing a controlled substance.

2. Security Risk Analysis (SRA)
A signed and dated copy of the annual SRA, completed anytime during 2025 if you are reporting the Promoting Interoperability (PI) category.

3. SAFER Guides
A completed, signed, and dated Safety Assurance Factors for EHR Resilience (SAFER) guide for 2025, which is also required for PI reporting.

4. Improvement Activities
Proof that at least one Improvement Activity was completed for small practices with 15 or fewer clinicians, or two for larger groups, even if submitted individually.

5. Promoting Interoperability Dashboard Screenshot
A screenshot showing your EHR’s PI category dashboard for a continuous 180-day reporting period.

6. Certified EHR CMS ID
The alphanumeric Certification ID for your EHR system, available from your vendor or the Certified Health IT Product List (CHPL) website.

7. Quality Category Data Files
All clinical quality measure data files submitted through your EHR, Qualified Registry (QR), or QCDR.

8. Submission Date and Acknowledgment
A screenshot or confirmation from the QPP portal showing the submission date and CMS receipt acknowledgment.

9. EUC Documentation
Proof of any Extreme and Uncontrollable Circumstances (EUC) exception claimed by the practice and granted by CMS.

10. Audit Trail and Access Logs
Maintain a secure record of submission history, version control, and access logs from your EHR or registry system to demonstrate traceability during an audit.

Each of these items must be retained for at least six years from the date of submission. CMS may request any of these records at any time during that period.

How to Stay Ready All Year

Audit readiness is not something to build after submission. It should be part of your routine.
Here is how to make it practical and sustainable:

Assign ownership early. Designate who collects, verifies, and stores each type of documentation.
Automate wherever possible. Use tools like MyMipsScore to timestamp uploads and create audit reports automatically.
Review quarterly. Conduct internal audits before CMS does.
Secure your storage. Store documentation in secure, encrypted formats and ensure continuity even if systems or staff change.

The timing could not be better. As the 2025 performance year progresses, this is the right moment to put your audit-readiness systems in place. Starting now gives you the advantage of a clean, organized process when submissions close and positions you to enter 2026 fully prepared, with nothing left to chase at the last minute.

How MyMipsScore Simplifies Audit Readiness

Manual tracking leaves room for errors. Files get misplaced, screenshots vanish, and version control becomes a guessing game.

MyMipsScore eliminates that risk. It automatically maintains your Book of Evidence with version control, timestamps, and linked measures. Each submission is traceable, transparent, and exportable for audits.

When CMS requests proof, you can provide it in minutes. MyMipsScore stores complete, audit-ready documentation for every reporting category and every performance year.

Audit readiness is not about fear. It is about confidence that comes with being prepared.
The right system turns compliance into a steady, repeatable process that safeguards your performance scores and reimbursement outcomes.

With MyMipsScore, your evidence is always organized, always available, and always defensible.