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CMS outlines data‑validation, retention and remedial actions for intermediaries
Summary
CMS told QCDRs and registries they must validate data prior to submission, retain records for six years, allow CMS audits of submitted data, and warned that failure to comply could lead to remedial action or termination.
John Jenkins described CMS' expectations for data stewardship and enforcement. He said intermediaries must retain records "for 6 years from the end of the MIPS performance period" and comply with any CMS request to review submitted data.
Jenkins walked through the data validation timeline: intermediaries should submit a data validation strategy at self‑nomination, conduct their validation before submitting data to CMS, and file the 2027 data validation execution report no later than May 31, 2028. He also described remedial actions and grounds for termination, including submission of false information, compromised data, or repeated noncompliance. "Failure to comply with remedial action process may lead to termination of 3rd party intermediaries for the current and or subsequent performance year," he said.
