To help radiology practices prepare for the Merit-Based Incentive Payment System (MIPS), we've prepared this quick primer that covers the latest changes to this complex program.
As most eligible clinicians (EC) already know, MIPS will begin to take effect for Medicare physician reimbursement in 2019, but payment adjustments will be determined by performance reported for 2017, which is being termed a "transitional year" for the program. The reporting period for 2017 has been lowered to a minimum of 90 days rather than a full year for all of the MIPS categories. It is expected that MIPS will be in full effect for 2018.
Quality will initially account for at least 60% of the total MIPS score, and Advancing Care Information (ACI) will account for up to 25% of the total score. The Improvement Activities (IA) category, originally called the Clinical Practice Improvement Activities category in proposed regulations, represents 15% of the total score for 2017, the first year of MIPS participation. The fourth element of MIPS, the Cost category, has been reweighted to zero for 2017.
Overview of the IA category
According to the U.S. Centers for Medicare and Medicaid Services (CMS) final rule governing MIPS, Improvement Activities are "those that support broad aims within healthcare delivery, including care coordination, beneficiary engagement, population management, and health equity." These activities have been identified as improving clinical practice or care delivery and are likely to result in improved health outcomes. There are 92 such activities available for eligible clinicians to choose from for 2017, each with a weight of either "high" or "medium."
Maria Calamaro from Healthcare Administrative Partners.High-weighted activities are worth 20 points each, and medium-weighted activities are worth 10 points each. To earn full credit for the IA category, a total of at least 40 points from any combination of activities is required -- for example, four medium-weighted, two high-weighted, or two medium- and one high-weighted activity.
For certain practices and eligible clinicians, the value of each activity is doubled so that high-weighted activities are worth 40 points and medium-weighted activities are worth 20 points. Thus, only one high-weighted activity or two medium-weighted activities would be necessary. These practices and eligible clinicians include the following:
- Small practices of fewer than 15 eligible clinicians
- Eligible clinicians located in a rural or health professional shortage area
- Eligible clinicians who are "nonpatient-facing"
An eligible clinician will be considered "nonpatient-facing" (NPF) if he or she has 100 or fewer Medicare Part B patient-facing encounters during the annual determination period. The initial determination period is September 2015 to August 2016 for the 2017 reporting period, with a second determination period of September 2016 to August 2017 to identify additional eligible clinicians who qualify as NPF.
Medicare will automatically determine whether an eligible clinician is classified as patient-facing or nonpatient-facing based on current procedural terminology (CPT) codes submitted; no action on the part of the clinician is required. Once an eligible clinician has been classified as NPF for a reporting period, he or she will continue to be considered NPF for the remainder of that reporting period. In other words, the second determination period cannot cause the removal of the NPF classification. The majority of radiology practices will be considered NPF and therefore will have to complete fewer Improvement Activities under MIPS.
Choosing Improvement Activities
The IA list includes 14 high-weighted and 78 medium-weighted activities within these eight subcategories:
- Achieving Health Equity (4 activities)
- Behavioral and Mental Health (8 activities)
- Beneficiary Engagement (23 activities)
- Care Coordination (14 activities)
- Emergency Response and Preparedness (2 activities)
- Expanded Practice Access (4 activities)
- Patient Safety and Practice Assessment (21 activities)
- Population Management (16 activities)
The choice of activities will depend on each practice's structure and data-gathering capabilities. Radiology practices will only have a small subset of the 92 possible activities that directly relate to their clinical practice, with the most applicable falling into the Beneficiary Engagement, Care Coordination, and Patient Safety and Practice Assessment (and possibly the Expanded Practice Access) subcategories. The other subcategories contain few activities that will apply to radiology in 2017.
Within the applicable subcategories, radiologists will find about a dozen that may be relevant, yet fewer that are actually achievable in the short run. Many activities will require the use of a Qualified Clinical Data Registry (QCDR) for reporting, along with new technology and changes to workflow processes to gather the requisite data.
The good news is that in the early years of MIPS, very few activities will be needed to satisfy the Improvement Activities category, especially when using group reporting. Over the longer horizon, radiology practices should establish a plan to address those activities that are of interest but not currently feasible, so they can be attained in subsequent years of MIPS.
The following table lists a few of the activities that radiology practices may want to consider.
| MIPS Improvement Activities relevant to radiology | ||
| Subcategory | Activity | Weight |
| Care Coordination | Performance of regular practices that include providing specialist reports back to the referring physician | Medium |
| Care Coordination | Timely communication of test results defined as timely identification of abnormal test results with timely follow-up | Medium |
| Care Coordination | Participation in the CMS Transforming Clinical Practice initiative | High |
| Beneficiary Engagement | Participation in a QCDR, demonstrating performance of activities that promote implementation of shared clinical decision-making capabilities | Medium |
| Patient Safety and Practice Assessment | Participation in other quality improvement programs such as Bridges to Excellence | Medium |
The full list of Improvement Activities available for 2017 is in Table H of the CMS Final Rule. It is reproduced here on the CMS Quality Payment Program website.
CMS has not yet provided any specifics about how each of the activities should be performed in practice to successfully satisfy the requirements. It is therefore up to the individual eligible clinician or practice to determine the method of implementation, tracking, and documentation to substantiate its performance for potential audit purposes. More guidance will become available through specialty societies and from CMS as time goes on.
Reporting Improvement Activities
The decision to report as individual eligible clinicians or as a group will require some balancing of pros and cons, and it will require a comprehensive look at all of the MIPS categories since reporting must be done consistently using one method or the other across all of the categories. For the Improvement Activities category, when reporting as a group, only one EC in the group needs to perform each selected activity -- and the entire group receives credit! This provides a heavy advantage to group reporting over individual EC reporting in the IA category, especially for larger groups.
The reporting of Improvement Activities will be done after the end of the year by attesting that the activities were completed through the use of a CMS-provided attestation system. This method is very similar to the previous CMS programs such as meaningful use, and it requires that documentation be kept to prove that activities were performed in the event of an audit by CMS.
Conclusion
Unlike Quality Performance and Advancing Care Information, which replace older CMS programs, the Improvement Activities category is totally new and will take some time to be fully understood. The following are some key concepts for radiology practices to remember about the IA category:
- Radiology practices with fewer than 15 eligible clinicians and those considered to be nonpatient-facing only need to report one high-weighted or two medium-weighted Improvement Activities to receive the full credit of 40 points.
- Only about a dozen or so Improvement Activities are currently applicable to radiology, and few are high-weighted.
- Most applicable IAs will be found in the Beneficiary Engagement, Care Coordination, and Patient Safety and Practice Assessment categories.
- Group reporting provides an advantage because a single individual's participation gives credit to the entire group.
Gathering the data for some Improvement Activities is labor-intensive and may require QCDR reporting, additional technology, and enhanced workflows -- which may be a stretch for practices in the near term. Practices should select the activities most readily achievable today and create a plan for future compliance with additional activities most meaningful to their clinical practice goals.
Although the performance year of 2017 allows for less than full participation, a higher level will be required in the years that follow. By putting an action plan in motion as early as possible, your practice will be in the best position to achieve optimized reimbursement in the future.
Maria Calamaro serves as product director for Healthcare Administrative Partners and is the company's subject-matter expert for CMS quality programs. She has more than 20 years of experience leading product development and direction-setting for physician and hospital healthcare applications.
The comments and observations expressed herein are those of the author and do not necessarily reflect the opinions of AuntMinnie.com.
