Posted on September 14, 2022
The MIPS Improvement Activities (IA) performance category measures a clinician or group’s engagement in clinical activities that improve clinical practice, care delivery, and outcomes. This year clinicians will need to attest to the Improvement Activities category, alongside reporting other MIPS categories, to ensure they reach the new minimum threshold of 75 points needed to avoid a MIPS penalty. The last day to start a new activity for a minimum 90-day reporting period is October 3, 2022. This article provides an overview of the IA category and offers tips on selecting activities most relevant to a clinician’s practice.
MIPS Improvement Activities (IA) - The Basics
The MIPS Improvement Activities (IA) category is designed to reward clinicians for participating in clinical practice improvement activities. It is one of four categories under the MIPS program and is worth 15% of the final MIPS score. CMS modified the performance category weight redistribution policies for small practices in 2022 to more heavily weight the IA category when the MIPS Promoting Interoperability (PI) and/or Cost categories are reweighted to 0%. The PI category will be automatically reweighted to 0% if PI is not reported by a small practice or small practice clinician.
The IA category will be weighted as follows for small practices in 2022:
- 30% for small practices when the PI category is reweighted to 0%
- 50% when both the PI and Cost categories are reweighted to 0%
Note the IA weight can also change based on a clinician’s participation in an Alternative Payment Model (APM) Entity participation.
Reporting the IA category involves a simple attestation process. Similar to the PI category, the IA category has a minimum continuous 90-day performance period unless otherwise stated in the activity description.
What's New in 2022?
There were some changes made to the Improvement Activities (IA) inventory in 2022. Many of the changes pertain to health equity and standardizing language related to equity across the activities.
CMS added 7 new activities to the IA inventory this year:
CMS removed 6 activities that can no longer be reported:
- IA_ BE_13 Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms
- IA_PSPA_11 - Participation in CAHPS or other supplemental questionnaire
- IA_BE_17 - Use of tools to assist patient self-management
- IA_BE_18 - Provide peer-led support for self-management
- IA_BE_20 - Implementation of condition-specific chronic disease self-management support programs
- IA_BE_21 - Improved practices that disseminate appropriate self-management materials
CMS also modified 15 existing activities:
Beginning in 2022 CMS will suspend an Improvement Activity if there is a reason to believe that the continued collection raises possible patient safety concerns or is obsolete. CMS notified clinicians in July that it was suspending IA_PSPA_30: PCI Bleeding Campaign under the Patient Safety and Practice Assessment subcategory for Traditional MIPS beginning with the calendar year 2022 performance period/2024 payment year. The PCI Bleeding Campaign ended in August 2021, making this activity obsolete for performance after that date.
List of 2022 Improvement Activities
There are over 100 Improvement Activities to choose from in 2022. All of the activities are divided into eight subcategories, and each activity is designated as “High-weighted” or “Medium-weighted”. Our website includes a filter to search by subcategory, or High or Medium-weighted activities.
|Expanded Practice Access||Population Management|
|Care Coordination||Beneficiary Engagement|
|Patient Safety and Practice Assessment||Achieving Health Equity|
|Integrating Behavioral and Mental Health||Emergency Preparedness and Response|
*Clinicians do not have to select activities in each subcategory nor select activities from a certain number of subcategories.
Reporting and Documentation Requirements
Clinicians reporting this category simply attest to performing an activity or activities for a minimum 90-day reporting period during the performance year. Most activities require a continuous 90-day reporting period, so the last day to start a new activity is October 3, 2022. This means clinicians and groups must start performing their improvement activities no later than October 3rd if they have not already started.
If a particular activity has a shorter or longer reporting period (e.g., IA_CC_10 Care transition documentation practice improvements has a 30-day reporting period) it will be specified in the activity’s description. Clinicians can generally attest to the same activity for multiple reporting years unless there are frequency restrictions specified in the activity documentation.
Important: When reporting as a group at least 50% of the clinicians in the group must perform the same activity during any continuous 90-day period, or as specified in the activity description, within the same performance year. The clinicians do not have to perform the activity during the same 90-day period.
Improvement Activity Criteria
For each activity, CMS has included an activity description and suggested documentation. This information should be carefully reviewed before completing the attestation to ensure the clinical activity being measured has been performed. Clinicians should have documentation demonstrating they performed the clinical activity as specified in the CMS description.
Additionally, it is important to note that Improvement Activities are not the same as Quality measures. Quality measures assess if a particular outcome occurred at a patient encounter. Improvement Activities indicate that the clinician has implemented clinical activities that improve clinical practice, care delivery, and outcomes overall.
Some examples of activities that might be confused with a Quality measure or are commonly misinterpreted:
- IA_BMH_2: Tobacco use. This activity involves regular engagement in integrated prevention and treatment interventions, including tobacco use screening and cessation interventions, for patients with co-occurring conditions of behavioral or mental health and at-risk factors for tobacco dependence. The clinical activity differs from Quality measure #226 Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention which is reported for eligible patients aged 18 years and older who were screened for tobacco use one or more times within 12 months AND who received tobacco cessation intervention if identified as a tobacco user.
- IA_PM_21: Advance Care Planning. This activity involves the implementation of practices/processes to develop advance care planning that includes: documenting the advance care plan or living will within the medical record, educating clinicians about advance care planning, motivating them to address advance care planning needs of their patients, and how these needs can translate into quality improvement, educating clinicians on approaches and barriers to talking to patients about end-of-life and palliative care needs and ways to manage its documentation, as well as informing clinicians of the healthcare policy side of advance care planning. This activity differs from Quality measure #047: Advance Care Plan which is reported on eligible patients aged 65 years and older who have an advance care plan or surrogate decision-maker documented in the medical record or documentation in the medical record that an advance care plan was discussed but the patient did not wish or was not able to name a surrogate decision-maker or provide an advance care plan.
- IA_AHE_6: Provide Education Opportunities for New Clinicians. This activity applies to clinicians acting as a preceptor for clinicians-in-training (such as medical residents/fellows, medical students, physician assistants, nurse practitioners, or clinical nurse specialists) and accepting such clinicians for clinical rotations in community practices in small, underserved, or rural areas. Clinicians must show evidence of clinical rotation assignments in community practices in small, underserved, or rural areas to attest to this activity.
Improvement Activity Documentation
Clinicians are not required to submit supporting documentation at the time of attestation. However, CMS requires that documentation be retained to confirm the completion of the activity for six years following the performance period in the event of an audit. CMS lists suggested documentation for each activity, but other general suggestions include:
- List the start date and end date for each activity.
- Describe the goals, outcomes, or metrics for each activity.
- Describe the process being improved and the benefit of improving the process.
- List the staff involved in each activity.
- List the technology used (if possible take screenshots).
- Describe workflows.
- Document improvement activities compliance.
- Describe monitoring systems to gauge your progress towards the goals.
- Store all documentation in computer files.
The number of activities required to maximize MIPS points for this category will depend on the size of the practice and any special status designation*. Attesting to more than the required number of activities will not increase a clinician or group’s MIPS score.
*Special status: Small practice, Rural, Health Professional Shortage Area (HPSA), Non-Patient Facing
TIPS on Selecting Improvement Activities
When selecting Improvement Activities, it is important to identify activities that are relevant to your practice and patient population.
✔Review suggestions for your specialty to see if any apply to your practice or if you are already performing any activities as part of your normal workflow.
✔Review the entire list of activities if none of the specialty recommendations apply to your practice.
✔Narrow the list of activities by subcategory, High or Medium-weight, to make the list more manageable.
✔If you are planning to report the MIPS Values Pathway (MVPs) in 2023, review the list of IAs associated with the MVP you may report and consider implementing the activity or activities this year. Each MVP will have specific IAs available as part of the MVP.
✔Look for activities you have already implemented in your practice. In some cases, you may be performing an activity but calling it by a different name.
✔Carefully review the activity description and suggested documentation to ensure you understand the CMS expectations and can provide documentation as proof that you completed the activity.
Some commonly reported Improvement Activities:
Improvement Activities that involve:
- Patient reminders of missed or overdue services:
- Prescription Monitoring Program / Opioid prescriptions:
- Placing and tracking orders and communicating test results:
- Identifying and caring for patients following a hospitalization or an emergency room visit:
- Review of targeted population needs:
- Dissemination of patient experience and satisfaction surveys:
- Participation in domestic and international volunteer activities:
- Pre-visit planning:
- Individualized care plans and medication management practices:
- Preventive health screenings and behavioral health services:
- Staff education and assessment:
- Telehealth services and chronic disease management support:
- Participation in community and national quality improvement programs:
- Case management, care transition and care coordination activities:
- Support from ancillary staff:
- Adoption of evidence-based performance improvement processes:
- EHR functionality:
- Practice workflow and EHR improvements to support care management and patient education:
Completing the Improvement Activities Attestation
Clinicians will need to attest to the MIPS Improvement Activities category in 2022, in addition to reporting other MIPS categories, to meet the higher minimum threshold of 75 MIPS points. There are over 100 activities to choose from, so clinicians should select activities that are relevant to their practice and support the needs of their patients. MDinteractive has posted Improvement Activities by specialty in addition to the full list on our website. The last day to begin a 90-day reporting period for IA is October 3, 2022.
MIPS Reporting MACRA Improvement Activities Attesting to Improvement Activities