Posted on September 25, 2023
Part 4 of our Mastering MIPS series covers the Improvement Activities (IA) performance category in the traditional MIPS program. This MIPS category assesses your engagement in various healthcare improvement activities designed to enhance patient care and outcomes. This article outlines the IA reporting requirements, explains the importance of reviewing the IA descriptions and suggested documentation, and offers tips on selecting activities that are right for your practice.
MIPS Improvement Activities (IA) - A Primer
The MIPS IA category measures your participation in activities that improve clinical practice. The performance period for most Improvement Activities is a minimum of 90 continuous days unless the activity description specifies otherwise. The final 90-day performance period to perform improvement activities begins October 2, 2023.
The IA category is generally worth 15% of the final MIPS score, but is more heavily weighted for small practices (15 or fewer clinicians) under certain circumstances:
- IA is worth 30% of the MIPS score for small practices if the MIPS Promoting Interoperability (PI) category is not reported (PI is automatically reweighted to 0% for small practices).
- IA is worth 50% of the MIPS score for small practices if both the PI and Cost categories are reweighted to 0%.
Note the IA weight can also change based on your participation in an Alternative Payment Model (APM) Entity.
What’s New in 2023?
There are over 100 Improvement Activities to choose from for the 2023 performance year. All of the activities are divided into eight subcategories, and each activity is designated as “High-weighted” or “Medium-weighted”. In 2023 CMS added four new activities, modified five existing activities, and removed six activities from the IA inventory as outlined in the table below.
How Do I Report the IA Category?
To report the IA category, simply attest to completing the activity for a minimum 90-day reporting period within the 2023 performance year. While the majority of activities must be performed for at least 90 days, a few activities have an alternate performance period so it's necessary to review the IA criteria before submitting your attestation.
The number of activities that must be attested to depends on the size of your practice and any special status designation* granted by CMS. Attesting to the required number of activities will ensure you maximize your IA score. If you don’t attest to implementing any activities, you’ll receive 0 points in this category.
|Clinicians in large practices (16 or more clinicians in the Tax Identification Number [TIN])||Clinicians in small practices (15 or fewer clinicians in the TIN) or who have another special status*|
- 2 High-weighted activities; OR
- 1 High-weighted activity and 2 Medium-weighted activities; OR
- 4 Medium-weighted activities
- 1 High-weighted activity; OR
- 2 Medium-weighted activities
*Special status: Small practice, Rural, Health Professional Shortage Area (HPSA), Non-Patient Facing
If you plan to report as a group, at least 50% of the eligible clinicians in the group must implement the same activity (or activities) during any continuous 90-day period (or as the period specified in the activity description) in the same performance year.
While many activities can be reported in consecutive performance years, certain activities impose restrictions on how often they can be implemented. For example, the IA_PSPA_4 Administration of the AHRQ Survey of Patient Safety Culture states that the activity can only be implemented once every 4 years. Any reporting restrictions will be noted in the IA criteria.
Do I Need Supporting Data for my IA Attestation?
CMS does not require supporting documentation for IAs at the time of submission. However, you will need to maintain documentation for 6 years following the submission in the event of an audit. Before attesting to an IA, carefully review the CMS description and suggested documentation to ensure you are performing the clinical activity being measured. Each activity contains examples of ways to demonstrate completion of the activity and clarifies the flexibilities clinicians have in implementing the activities.
CMS lists the following common examples of suggested documentation:
- Screenshot or digital capture of relevant information supporting the attestation.
- Improvement plans and/or outlines supporting the interventional strategies/processes implemented to meet the intent of the improvement activity.
- Electronic Health Record Report: Retain a copy of documentation relevant to the chosen improvement activity as evidence of attestation.
Do any of the Quality Measures I report also contribute to my Improvement Activities?
No. The Improvement Activities are not the same as the Quality measures you may have reported under the MIPS Quality category. 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 involves the implementation of practices to develop advance care planning, including documenting it in medical records, educating clinicians, and addressing barriers to discussing end-of-life and palliative care needs. It also includes informing clinicians about healthcare policy aspects related to advance care planning. In contrast, Quality measure #047 Advance Care Plan assesses whether eligible patients aged 65 years and older have an advance care plan or surrogate decision-maker documented in the medical record or if there's documentation that the plan was discussed but the patient didn't wish or couldn't provide one.
TIPS on Selecting Your Improvement Activities
When selecting Improvement Activities, identify activities that are relevant to your practice and unique 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.
- If you are planning to report the MIPS Values Pathway (MVPs) in 2023, implement an activity (or activities) associated with the MVP. Each MVP will have specific IAs available as part of the MVP.
- Narrow the list of activities by subcategory, High or Medium-weight, to make the list more manageable.
- 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.
- Attesting to more than the required number of activities will not increase your MIPS score.
The final 90-day continuous performance period to perform Improvement Activities begins October 2, 2023. If you haven’t already started performing your improvement activities, you must do so no later than October 2nd. Ensure that you have selected the activities you intend to attest to and have a clear understanding of the necessary documentation that is needed to demonstrate your completion of these activities.
2023 MIPS 2023 MIPS Improvement Activities Improvement Activities Documentation