MIPS improvement activities requirement is in place to help clinicians show that they have completed up to four improvement activities for the required period of time.
The Merit-based Incentive Payment System (MIPS) is one way to participate in the Quality Payment Program. Under MIPS, you earn a payment adjustment for Part B covered professional services based on our evaluation of your performance across different performance categories. These categories focus on the quality and cost of the patient care you provide, improvements to your clinical care processes and patient engagement, and your use of certified electronic health record technology (CEHRT) to support and promote the electronic exchange of health information.
If you’re eligible for MIPS for a given performance year:
- You generally have to report measure and activity data for the quality, improvement activities, and Promoting Interoperability performance categories, collected during the performance year.
- Your performance across the MIPS performance categories, each with a specific weight, will result in a MIPS final score of 0 to 100 points.
- Your MIPS final score will determine if the payment adjustment applied to your covered professional services is negative, neutral, or positive.
MIPS Reporting Frameworks
There are 3 MIPS reporting frameworks available to MIPS eligible clinicians:
- Traditional MIPS, established in the first year of the Quality Payment Program, is the original framework for reporting to MIPS. You select the quality measures and improvement activities that you will collect and report, in addition to the complete Promoting Interoperability measure set. We collect and calculate data for the cost performance category for you.
- The Alternative Payment Model (APM) Performance Pathway (APP),is a streamlined reporting framework for clinicians who participate in a MIPS APM. The APP is designed to reduce reporting burden, create new scoring opportunities for participants in MIPS APMs, and encourage participation in APMs.
- MIPS Value Pathways, or MVPs, are a reporting framework that will offer clinicians a subset of measures and activities, established through rulemaking, that are relevant to a specialty, medical condition, or episode of care. MVPs are tied to our goal of moving away from siloed reporting of measures and activities towards focused sets of measures and activities that are more meaningful to a clinician’s practice, specialty, or public health priority. We finalized 7 MVPs in the CY 2022 Physician Fee Schedule Final Rule for reporting to begin with the 2023 performance year.
Traditional MIPS, established in the first year of the Quality Payment Program, is the original framework available to MIPS eligible clinicians for collecting and reporting data to MIPS. Your performance is measured across 4 areas – quality, improvement activities, Promoting Interoperability, and cost. MIPS eligible clinicians who are also participants in MIPS APMs also have the option to report via the APM Performance Pathway (APP).
Beginning in the 2023 performance year, clinicians will also have the option to report via the MIPS Value Pathway (MVP)s framework instead of traditional MIPS.
How It Works
You submit the quality and Promoting Interoperability measures and improvement activities you collect/perform during the performance year. We collect and calculate cost measures for you. The 4 performance categories are scored and make up your MIPS final score. Your final score determines the payment adjustment adjustment applied to your Medicare Part B claims. These categories are:
This performance category assesses the quality of the care you deliver, based on performance measures created by CMS, as well as medical professional and stakeholder groups. You pick the 6 quality measures that best fit your practice.
Promoting Interoperability (PI)
This performance category promotes patient engagement and the electronic exchange of health information using certified electronic health record technology (CEHRT). You report a single set of Promoting Interoperability objectives and measures.
This performance category assesses how you improve your care processes, enhance patient engagement in care, and increase access to care. You choose the activities appropriate to your practice
This performance category assesses the cost of the patient care you provide. We calculate cost measures, based on your Medicare claims, to determine the cost of the care you provide to certain patients.
MIPS was designed to tie payments to quality and cost efficient care, drive improvement in care processes and health outcomes, increase the use of healthcare information, and reduce the cost of care.
The MIPS performance year begins on January 1 and ends on December 31 each year. If you’re eligible for MIPS, you must report data collected during the calendar year by March 31 of the following calendar year. Payment adjustments, based on the data you submit for services provided, are applied to Part B claims during January 1 to December 31 of the year following data submission. For example, if you collect data between January 1 – December 31, 2022 (the performance year), you must report your data by March 31, 2023, and will receive a MIPS payment adjustment between January 1 – December 31, 2024 (the payment year).
Choose How You Will Participate
It’s possible to participate and collect and report your data to MIPS in multiple ways. When reporting via traditional MIPS, you can participate as an individual, group, virtual group or APM Entity. If you’re required to participate in MIPS, you’ll receive a payment adjustment based on the data you submit or don’t submit.
A practice can choose to collect and report aggregated data at the group level on behalf of all its clinicians. The clinicians in the practice that are MIPS eligible at the group level will receive a payment adjustment based on the group’s final score. The clinicians in the practice that are MIPS eligible at the individual level will receive a payment adjustment based on the group’s final score unless they have a higher final score from individual or APM Entity participation.
Clinicians can collect and report data representing their individual performance. Clinicians that are MIPS eligible at the individual level will receive a payment adjustment based on their individual final score unless they have a higher final score from group or APM Entity participation. Note: If you’re MIPS eligible at the individual level, then you’re required to participate in MIPS, either as an individual, group, virtual group or APM Entity
Clinicians can elect to form a virtual group. CMS approved virtual groups collect and report aggregated data on behalf of all its clinicians. The MIPS eligible clinicians in the virtual group will receive a payment adjustment based on the virtual group’s final score, even if they participate as an individual, group or APM Entity.
An APM Entity can choose to collect and report aggregated data at the Entity level on behalf of its MIPS eligible clinicians. (We note that Promoting Interoperability data is still reported at the individual or group level when participating at the Entity level.) The clinicians in the APM Entity that are MIPS eligible at the individual or group level will receive a payment adjustment based on the APM Entity’s final score unless they have a higher final score from individual or group participation.