The Improvement Activities component is one of the four Merit-Based Incentive Payment System (MIPS) performance categories under which MIPS–eligible clinicians, including psychiatrists, will be assessed for potential adjustments to their Medicare Part B payments.
How Much Do Improvement Activities Count in My MIPS Score?
For year one (2017) reporting (and subsequent 2019 payment adjustments), as well as future years, Improvement Activities will account for 15% of your total MIPS Composite Score. If reporting as part of a group, the group will receive one MIPS Composite Score that applies to all its eligible clinicians.
How does the Improvement Activities Category Compare to Previous Medicare Requirements?
Unlike with the MIPS categories of Quality and Advancing Care Information, CMS has not previously asked psychiatrists to report on these types of activities. When Congress passed the Medicare Access and CHIP Reauthorization Act (MACRA) it wanted to recognize and reward physicians for activities they routinely engage in that improve the quality of their patient care.
What Can I Do to Prepare for This Category?
CMS has recognized 92 activities as Improvement Activities. Review the list of activities to see which are appropriate for you or your practice.
Improvement Activities Reporting
What Do I Need to Report?
To receive full credit (100%, or 40 points), most psychiatrists will need to engage in two high-weighted activities (worth 20 points each) or four medium-weighted activities (worth 10 points each), or some combination thereof, for at least 90 continuous days during the performance year.
You have full discretion to select activities that are most applicable to your practice. Activities are provided in several categories:
- Integrated Behavioral and Mental Health
- Expanded Practice Access
- Population Management
- Care Coordination
- Beneficiary Engagement
- Patient Safety and Practice Assessment
- Achieving Health Equity
- Emergency Response and Preparedness
- A psychiatrist only needs to report on one high-weighted or two low-weighted activities for full credit (100% score), or one medium-weighted activity for half credit (50% score), if you are:
- Part of a small group practice with 15 or fewer clinicians;
- Located in a rural area;
- Located in a geographic health professional shortage area, or
- Considered a "non-patient-facing" clinician who bills for 100 or fewer "patient-facing" encounters during a 12-month period. If reporting as a group, more than 75% of the clinicians with individual National Provider Identifiers (NPIs) billing under the group’s tax identification number (TIN) must meet the definition of being non-patient facing. Telepsychiatry (and other telehealth) services are considered "patient-facing."
- Psychiatrists who practice in certain alternative payment models (APMs), but didn’t deliver enough care under the APM to fall into the APM payment pathway, receive full credit — 100% &mdash for the Improvement Activities Category for 2017. You are considered an APM participant if you are listed on the APM’s participation list. CMS will automatically apply this status to you and you don’t need to attest to any improvement activities. For 2017, CMS recognizes the following APMs for purposes of getting a 100% score:
- Shared Savings Program Tracks 1, 2 and 3
- Next Generation ACO Model
- Comprehensive End-Stage Renal Disease (ESRD) Care Model (all arrangements)
- Oncology Care Model (OCM) (all arrangements)
- Comprehensive Primary Care Plus (CPC+) Model
How Do I Report? When Do I Report?
Under the Improvement Activities category, you or your group must attest to CMS with a Yes or No response on whether you performed the selected activities. This is the only MIPS category that involves a simple attestation, and it can be submitted directly to CMS. Or, it can be submitted on your behalf by your health information technology (IT) vendor, qualified clinical data registry (QCDR), or qualified registry. Groups of 25 or more eligible clinicians have the additional option to report via the CMS Web Interface. The deadline for data submission to CMS is March 31, 2018. CMS is considering an earlier submission deadline for use of the CMS Web Interface.
Your Improvement Activities Score
How is the Improvement Activities Category Scored?
To achieve the highest potential score for the IA category, a psychiatrist needs to achieve a total of 40 points for a 100% score. Each Improvement Activity is a "high-weighted" or a "medium-weighted" activity. High-weighted activities count for 20 points each, and medium-weighted activities count for 10 points each.
For the 2017 performance period (and reporting year), the CMS Inventory includes 79 medium-weighted activities and 14 high-weighted activities. High-weighted activities are those which CMS considers to align with its national priorities and programs, require the performance of multiple activities, involve treating Medicaid patients, or relate to a public health priority. These include some activities involving collaborative mental health care, as well as participation in activities related to the CMS Transforming Clinical Practice Initiative (TCPI). Psychiatrists can earn credit as an Improvement Activity for undergoing training in the Collaborative Care Model developed by the AIMS Center of the University of Washington. The APA provides this training through our participation in the TCPI.
If you capture certain activities using Certified Electronic Health Record Technology (CEHRT) you may also qualify for a bonus towards your score in the MIPS Advancing Care Information performance category. Those Improvement Activities are indicated with an asterisk (*) in the list in the Appendix.
Appendix: Improvement Activities for 2017 MIPS Reporting
Download the list of all 92 MIPS Improvement Activities in the CMS Inventory for the 2017 performance and reporting year. None of these activities are mandatory. It is up to each psychiatrist or practice to select those that are most appropriate for your practice and your patients. The asterisk (*) indicates activities for which you may earn a bonus under the MIPS Advancing Care Information category, if captured using certified electronic health record technology (CEHRT).
Download MIPS Improvement Activities List
What should I do if I have questions or issues regarding Medicare quality and payment reform?
APA members can submit questions by email to APA staff at email@example.com.
What other resources are available?