In Part 4 of this series we walked you through the Advancing Care Information Category of the MIPS Payment Track for MACRA’s Quality Payment Program (QPP). This article will walk you through the 4th or final category of the MIPS payment track, the Improvement Activities category. Initially, this category was named “Clinical Practice Improvement Activities.” However, in the Final Rule the name was simplified to “Improvement Activities.”
Fortunately, that’s not the only change that the Final Rule made to the Improvement Activities category. Originally, every practice was required to earn a total of 60 points, regardless of size. However, the Final Rule provided relief for practices with 15 or less eligible clinicians, requiring them to only achieve a total of 40 points. This means they are required to do fewer activities than larger practices are.
The Improvement Activities category is the new kid on the block. It doesn’t replace any previously existing quality program. Clinicians are rewarded for practices that focus on improvement activities such as care coordination, beneficiary engagement, and patient safety. Clinicians will attest that they have completed up to four activities for a minimum of 90 days. Those practices with 15 or fewer clinicians will only be required to attest that they have completed up to 2 activities for a minimum of 90 days. Alternatively, participants in certified patient-centered medical homes, comparable specialty practices, or an APM designated as a Medical Home Model will automatically earn full credit. Additionally, participants in certain APMs under the APM scoring standard, such as Shared Savings Program Track 1 or OCM will automatically be scored based on the requirements of participating in the APM. Participants in any other APM will automatically earn half credit and may report additional activities to increase your score.
There are a total of 92 activities to choose from in the Improvement Activities category. Some activities are weighted heavier than others. In fact, 14 of the 92 activities are designated as “High” weighting and are worth 20 points each. For small practices of 15 or fewer clinicians you can earn your 40 points by participating in two of these activities. Alternatively, 78 of the activities are weighted as “medium” and are only worth 10 points each. It would take four of these activities to achieve your 40 points. This seems like a more difficult path to follow but you might be surprised at the number of these activities you already participate in. Especially for those of you who offer chronic care management (CCM) services. You can find a full list of these activities here: https://qpp.cms.gov/measures/ia.
The Improvement Activities category will contribute 15% to your total Composite Performance Score (CPS). Again, you can earn up to 60 points for practices that have 16 or more eligible clinicians or up to 40 points for practices with 15 or fewer eligible clinicians. It’s also important to note that for this category, you can choose to report as a group or as an individual.
Here are some examples of success in this category: High-Weighted Activities
- Population Health will be huge moving forward. Use of a Qualified Clinical Data Registry (QCDR) for feedback reports that incorporate population health is a highly-weighted activity that will earn you 20 points. Having the right EHR is vital to making this activity an easy one. Ask your vendor if they are planning to support population health and how they will be doing that. Being able to identify at-risk populations and their treatment outcomes will be an easy way to achieve success here.
- Engaging new Medicaid patients and following up with Medicaid patients in a timely manner is another easy, but highly-weighted Improvement Activity. This includes patients who are dually eligible for Medicaid and Medicare. When combined with Population Health, this activity will add another 20 points and quickly help smaller practice achieve the required 40 points.
- Chronic Care Management (CCM) will be essential to success in medium weight categories. Specifically, care coordination agreements that promote improvements in patient tracking across settings is an activity that you’ll already be participating in if you offer CCM services to your patients. This activity is worth 10 points.
- Chronic care and preventative care management for empaneled patients is another activity that is covered for practices that offer CCM services. When combined with the care coordination activity above, this 10-point activity will get you to 20 points right away.
What If you offer CCM services and have a Population Health module in your EHR? Then your quickest path to being successful in the Improvement Activities category of MIPS is to participate in the high-weighted population health activity and both medium-weighted care coordination activities listed above. For smaller practices, these three activities will equal the 40 points required for success in this category.
Now that we’ve walked you through the final category of MIPS, stay tuned for the next article in this series where we will break down how your actual scoring is compiled for the 2017 transitional year and beyond.