2019 MIPS Improvement Activities

The Improvement Activities (IA) category was a new performance category introduced for the 2017 Merit-based Incentive Payment System (MIPS) performance year by the Centers for Medicare & Medicaid Services (CMS). The IA category is intended to reward clinicians for care focused on coordination, beneficiary engagement, and patient safety. Below are key questions to keep in mind and the list of pathology specific Improvement Activities for the 2019 MIPS performance year. The CMS reviewed and approved the IAs and suggested documentation included in this document as potentially applicable to pathologists.

The IA category does not have a precedent the CMS program and is a new category introduced for the MIPS. The IA category is intended to reward clinicians for care focused on coordination, beneficiary engagement, and patient safety.

Improvement Activites account for 15% of a non-patient-facing physician’s MIPS score (for most pathologists the other 85% is Quality Measures. However, if in some instances CMS is able to attribute Cost measures to pathologists in which case Cost is 15% and Quality is 70% of the overall MIPS score; IA will remain at 15%).

Improvement Activites are classified as high-weighted (worth 40 points) and medium-weighted (worth 20 points). The CAP recommends you choose either two medium-weighted or one high-weighted IA.

• Physicians must do the activity for a minimum of 90 days and up to a full year.
• Physicians must keep documentation for 10-years on how they participate in an Improvement Activity.

Many activities pathologists are already doing should qualify for Improvement Activities. According to data collected by the CAP’s 2017 MIPS Reporting Solution, some of the top utilized Improvement Activities by pathologists were:

• Implementation of improvements that contribute to more timely communication of test results (medium weight = 20 points)
• Implementation of use of specialist reports back to referring clinician or group to close referral loop (medium weight = 20 points)

Please refer to the IA document that the CAP has developed for more guidance on which IA to attest.

Physicians must attest to completing the Improvement Activities by the end of the 2019 MIPS reporting period.

• A simple “yes” is all that is required to attest to completing an improvement activity, in addition to documentation
• Most billing companies cannot provide attestation for Improvement Activities. Therfore, most pathologists will need to attest, such as through a qualified registry, for Improvement Activities. (Groups of 25+ can submit through the CMS web interface).
• For group reporting, only one MIPS-eligible clinician in a tax identification number (TIN) entity must perform the Improvement Activity for the TIN to receive credit.

Visit the CMS website for more information on Improvement Activities: https://qpp.cms.gov/mips/improvement-activities.

Members can login to see Improvement activities we have identified as applicable to pathologists.