What is IVA in risk adjustment?
The Department of Health and Human Services (HHS) Risk Adjustment Validation (RADV) Audit Initial Validation Audit (IVA) is
an annual audit designed to validate the information received by the Centers for Medicare and Medicaid Services (CMS).
Per the CMS RADV protocols, there are six pieces to the RADV process:
- CMS creates a sample of a health plan’s enrollee records for audit.
- The health plan must select an initial validation auditor to audit demographic and enrollment data, prescription drug categories (RXCs), and health status data submitted on the health plan’s External Data Gathering Environment (EDGE) server for the selected sample enrollees.
- A second validation auditor performs a quality assurance audit on a subsample of the initial validation auditor’s data to verify the accuracy of the findings.
- CMS performs error estimations and calculates the health plan’s risk score error rates using the failure rate of each HCC.
- CMS administers the second validation audit findings attestation and discrepancy reporting process, the error rate attestation and discrepancy reporting process, and an administrative appeals process.
- Final results are used to adjust the risk adjustment risk scores and transfers.
IVA auditors follow six steps to perform the member demographic & enrollment, medical claims and diagnostic validation, according to a
CMS presentation on the RADV-IVA process. Here’s how to prep for your IVA vendor to maximize RADV audit performance based on those steps.
1) Issuer identifies source data and performs mapping of data
Document your process for mapping Source System data to EDGE data submissions. Specify the screens on which your
IVA vendor can find information it needs to validate EDGE data elements such as Unique Enrollee ID, cost-sharing reductions and billing type codes. Provide step-by-step navigation for accessing these screens as well. You must also clarify how your IVA auditor can determine if claims are capitated and explain how supplemental diagnoses are identified. All of this documentation will help your IVA vendor validate data.
2) Review and confirm mapping of data
Your IVA vendor will review with you the documentation that you provided in the first step to confirm their understanding of your enrollment, premium and claims source systems. They will then create work papers that will include your documentation as well as their procedures for validating data with supporting screenshots. Upon your approval, they will start using these work papers to validate demographics, enrollment and claims data. So, the better you document and explain your mapping process from the audit’s outset, and the more detailed you are in assessing their work papers, the sooner they can begin validating data and the more efficiently they can complete the project.
3) Perform enrollment and demographics validation
Your IVA vendor will check if demographics and enrollment data matches on the EDGE server and your source systems. Every record will be checked. Avoid discrepancies by confirming that masked unique enrollee IDs from the EDGE server link to actual enrollee identifiers. Your IVA will be checking matches of 14 fields between the source system image and the EDGE server report.
4) Perform medical claims data validation
CMS requires IVA auditors to follow a separate five-step process for
medical claims data validation.
- The auditor compiles the population of claims to be sampled from the RADV Medical Claim Extract Report.
- They then randomly choose 15 to 130 claims for sampling. They will start with 15 claims but gradually increase the sample size up to 130 claims as more are deemed to have errors. You will fail claims validation if 15 claims have errors.
- Each claim is assessed for validation of 11 claims data elements, including final adjudication status and service code(s). Your auditor will check against source documentation. Prepare to provide additional documentation for capitated encounter data, like how EDGE data was populated and how the encounter was allowable within RA criteria.
- The reviewer identifies and documents all errors between your source systems and the RADV Medical Claims Extract Report. They will deem any claim that has at least one discrepancy in claims data elements as containing errors.
- Validation will end or your sample size will increase based on the number of claims with errors in the current sample. For example, if none of the 15 claims initially sampled have an error then your auditor will cease validation. If at least one of those first claims has an error, then the sample size will increase to 25 claims. You can then have no more than one claim with an error. Again, the sample size could gradually increase up 130 claims, in which only 14 claims can have errors, otherwise, you will fail claims validation.
5) Conduct medical record documentation review to substantiate each member HCC
The issuer must provide the IVA vendor with source medical record documentation to validate submitted medical claims and supplemental diagnoses for Risk Adjustment data for each sampled enrollee. Issuers are responsible for making all necessary documents accessible to the IVA vendor. The review of enrollee health status must be conducted by certified medical coders accredited by a nationally recognized accrediting agency such as:
- American Health Information Management Association (AHIMA), or
- American Academy of Professional Coders (AAPC).
If a discrepancy between issuer submitted diagnoses and the medical record is uncovered during the data validation audit process and the result would cause a change to the enrollee’s risk score, then a risk adjustment error would be reported by the IVA vendor to CMS. A risk adjustment error could be the result of incorrect demographics data, or due to an unsupported HCC diagnosis, or a new HCC diagnosis identified during the
medical record review. If a risk adjustment error is identified, the error must be validated by having a senior reviewer from the IVA vendor confirm each error. A “senior reviewer” is a reviewer certified as a medical coder by a nationally recognized accrediting agency who possesses at least five (5) years of experience in medical coding.
6) Record validation results
Your auditor will document in the IVA Audit Tool the results of its comparisons of data from the EDGE server and your source systems, including demographics, enrollment and claims data. The matrix will then be included in your final submission package along with supporting documentation and work papers.
Given that CMS will use audit results to adjust risk adjustment payments, beginning with 2016-benefit-year data, prep for your IVA vendor based on the process that they will follow, so that you can maximize RADV Audit performance.
IVA auditors follow 6 steps to validate membership, claims, and diagnosis. Here’s how to prep for your IVA vendor to maximize RADV audit performance.
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Learn why your coding skills are important during an RADV audit.
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