The MIPS Improvement Activity (IA) performance category was a new category in 2017; there was no analogous program in previous years. For 2020, with the exception of a few added and removed activities, it remains largely unchanged. The IA category requires eligible practitioners to attest to completing a certain number of CMS-approved activities over the course of the year, with each activity taking place over at least 90 days. This category will count for 15% of the overall MIPS Performance Score. Beginning with the 2020 performance year, physicians participating in MIPS as a group must attest that at least 50% of the NPIs within the group TIN participated in each activity submitted by the group.
Your IA score is determined by the number of points earned divided by the maximum number of points (40). The IA score is then weighted by 15% when calculating your final MIPS score.
The number of required activities depends on whether the group or individual is considered “patient facing” or “non-patient facing.” If an individual or group practice has billed more than 100 patient facing encounter codes in the past year, they will be considered patient facing. CMS has released the list of all patient facing encounter codes to help physicians determine their status. For more information, see ACR’s Patient Facing Clarification write-up.
For groups of more than 15 patient facing clinicians, medium-weighted activities count for 10 points each, and high-weighted activities are worth 20 points. For non-patient facing clinicians, groups of 15 or fewer clinicians, or those in rural or health professional shortage areas, point values are doubled so that medium-weighted activities are 20 points and high-weighted activities are worth 40 points.
You may use any combination of activities that adds to 40 points.
Patient facing clinicians are required to attest to either two high-weighted Improvement Activities or four medium-weighted activities, while non-patient facing clinicians, groups of fewer than 15 participants and those in rural or health professional shortage areas only have to attest to one high-weighted activity or two medium-weighted activities.
For MIPS reporting, only an attestation is required to receive points for completing Improvement Activities. However, please note that at some point in the near future CMS will be releasing suggested documentation for each activity. In the event of an audit, practices will need to ensure they have documentation confirming the completion of the activity.
Attesting and Submitting Activities
Participants in the ACR’s NRDR QCDR can attest to Improvement Activities using the MIPS Portal at https://nrdr.acr.org. Those who choose to submit using Claims or Qualified Registries can attest to Improvement Activities using a web interface soon to be available on the CMS website.