QUALITY PAYMENT PROGRAM Improvement Activities Performance Category

The Merit-based Incentive Payment System or MIPS is one of two participation paths of the new Quality Payment Program or QPP. The Quality Payment Program, contained within MACRA, the Medicare Access and CHIP Reauthorization Act of 2015, is part of a broader effort by CMS, the Centers for Medicare and Medicaid Services, to shift from a volume based payment system, to one which rewards clinicians demonstrating high quality and value by penalizing those who are not. The QPP replaces and consolidates several legacy Medicare programs, combining them into a single program with flexibility that allows participants to choose the activities and measures which are most meaningful. MIPS consolidates the Physician Quality Reporting System or PQRS, now the Quality performance category of MIPS, the Value-modifier program, now the Cost performance category, the Medicare EHR Incentive Program, now the Advancing Care Information performance category and adds a new fourth performance category called Improvement Activities.

The performance of MIPS participants, referred to as Eligible Clinicians or ECs, is measured across the four weighted performance categories on a 100 point scale, called the Final Score, which is then compared against an annual performance threshold, with Medicare Part B reimbursement rates adjusted based on program performance. In the first Transition Year of the program, to give participants additional time to prepare, clinicians will not be assessed using the Cost performance category, thus only 3 of the 4 MIPS performance categories will be used in 2017. In this initial year of the program, the Quality performance category is worth 60% of the Final Score, the Improvement Activities performance category is worth 15% of the Final Score, and the Advancing Care Information performance category is worth 25% of the Final Score.

In the Improvement Activities performance category of MIPS, participants attest to having implemented activities that improve the clinical practice for a minimum of 90 days in the calendar year. There are currently 94 activities available to choose from which span the following 9 subcategories: Expanded Practice Access, Population Management, Care Coordination, Beneficiary Engagement, Patient Safety and Practice Assessment, Participation in an Alternative Payment Model, Achieving Health Equity, Integrating Behavioral and Mental Health and Emergency Preparedness and Response. The improvement activities for MIPS were based on the Patient Centered Medical Home model, so if you are familiar with that program, you will likely be familiar with the activity choices. Additionally, many clinicians, even those not practicing in Medical Homes, will likely identify activities on the list which have been previously implemented, sometimes years ago. Participants can get credit for previously implemented activities as long as the activity continues for a minimum of 90 days in the performance year.

Each of the 94 available activities is rated as either Medium weight, worth 10 points each or High weight, worth 20 points each. To maximize this category scoring, participants must achieve 40 points, which can be achieved with any combination of Medium and High weight activities. If selecting the “Submit Something” route in the Pick Your Pace options in 2017, participants simply looking to negate the 4% payment penalty can do so by attesting to 1 improvement activity. Partial and full year participation requires achieving the full 40 points, however, there are some additional flexibilities built into the program.

For groups with 15 or fewer participants, non-patient facing clinicians or groups, or if practicing in a rural or health professional shortage area, improvement activity point values are doubled, thus for these clinicians, category scoring can be maximized with 1 high weight activity or 2 medium weight activities. Additionally, clinicians practicing in all types of certified patient-centered medical homes, comparable specialty practices, or Alternative Payment Models designated as Medical Home Models automatically receive full credit in this MIPS performance category. Also, participants of a Medicare Shared Savings Program Track 1 ACO or the Oncology Care Model receive Improvement Activities category credit based on the requirements of participating in the APM. In 2017, this is full credit at 40 points. In future program years, this participation will be worth at least half credit.

To calculate the Improvement Activities Performance Category Score, take the total number of points scored for completed activities divided by the maximum number of points available in the performance category and multiply by 100.

In summary, the Improvement Activities performance category of MIPS is worth 15% of the Final Score in 2017. Clinicians choose from 94 activities spanning 9 subcategories. To qualify for points, the activities must be implemented for a minimum of 90 days in the program performance year. Clinicians can maximize category potential at 40 points with medium-weight activities worth 10 points each and high-weight activities worth 20 points. For groups with 15 or fewer clinicians, non-patient facing clinicians, or if practicing in a rural or health professional shortage area, activities are worth double points. Participants in certified Medical Homes automatically earn full category credit. Participants of MIPS APMs, including Shared Savings Program Track 1, automatically earn full category credit in 2017. In future years, this assigned score will be at least half credit.