January 6, 2016
MIPS: What you need to know about Clinical Practice Improvement Activities
This piece of the MIPS puzzle is a new performance category for CMS, and it’s weighted 15 percent of the MIPS total score. Clinicians choose from 90 activities (each assigned to a sub-category) that have been designed with the intention of measuring capabilities in areas like care coordination, beneficiary engagement and patient safety.
60 points = 100 percent credit
Clinicians who are part of a PCMH will automatically receive 100 percent credit for this performance category, APM participants (who do not qualify as an Advanced APM QP) automatically receive 50 percent credit for this category. For providers in groups of fewer than 15, CMS proposes to require them to complete any two CPIAs for full credit in the category.
CMS proposes to weigh activities either high or medium. High-weighted activities are worth 20 points and medium-weighted activities are worth 10 points. Each eligible clinician must perform these activities for at least 90 days in year one and earning fewer than 60 points will only earn providers or groups partial credit. Special scoring considerations will be made for small practices with fewer than 15 providers, rural practices, among other exceptions.
Some of the CMS proposed sub categories of activities are as follows:
- Expanding practice access
- Population management
- Care coordination
- Beneficiary engagement
- Patient safety and practice assessment
- Achieving health equity
- Integrating behavioral and mental health
- Emergency Response and Preparedness
Examples of high-weighted activities include Beneficiary Engagement and Patient Safety and Practice Assessment, and examples of medium-weighted activities are Care Coordination and Population Management. Providers may complete any combination of high- or medium-weighted activities to achieve a total of 60 points. You can find a full list of proposed activities on page 946 of the MACRA proposed rule. CMS has indicated that they hope to create baseline requirements for year one, and then put in place more stringent requirements in future years.
Providers have several submission options, including EHR submission mechanisms. However, in addition to data submission, a "MACRA-ready" EHR should keep you aware of how you're performing at all times in an easy-to-view dashboard, and should also provide you with a worklist of patients to take action on in order to improve your score. Make sure your software has the intelligence and features to help you succeed through this transition.