MIPS Imprvement Activities Perfrmance Categry The Imprvement Activities cmpnent is ne f the fur Merit-Based Incentive Payment System (MIPS) perfrmance categries under which participating MIPS eligible clinicians, including psychiatrists, will be assessed fr ptential adjustments t their Medicare Part B payments. The MIPS is part f the Quality Payment Prgram (QPP), alng with incentives fr advanced alternative payment mdels. Hw D Imprvement Activities Fit Int MIPS? Fr the 2017 and 2018 perfrmance years, and cntinuing in subsequent perfrmance years, Imprvement Activities will accunt fr 15% f yur ttal MIPS Cmpsite Scre. If reprting as part f a grup practice r virtual grup, the grup will receive ne MIPS Imprvement Activity scre that applies t all f its eligible clinicians. Hw Des the Imprvement Activities Categry Cmpare t Previus Medicare Requirements? Unlike the ther MIPS perfrmance categries, CMS had nt previusly asked psychiatrists t reprt n Imprvement Activities. When Cngress passed the Medicare Access and CHIP Reauthrizatin Act (MACRA), it included this new reprting categry t recgnize and reward physicians fr activities that imprve the quality and efficiency f their patient care. IMPROVEMENT ACTIVITIES REPORTING What Are the MIPS Imprvement Activities? Fr perfrmance year 2017, CMS recgnized a ttal f 92 Imprvement Activities. These include 78 medium-weighted and 14 high-weighted activities. High-weighted activities are thse which (a) align with CMS natinal pririties and prgrams; (b) require the perfrmance f multiple activities; (c) invlve treating Medicaid patients; r (d) relate t a public health pririty. Fr perfrmance year 2018, CMS made sme changes and expanded the list t a ttal f 112 activities. These include 89 medium-weighted and 14 high-weighted activities. Psychiatrists can dwnlad the cmplete list fr 2018 by ging t https://www.cms.gv/medicare/quality-payment-prgram/resurce- Library/2018-Imprvement Activities.zip.
Psychiatrists have full discretin t select activities that are mst applicable t their practice. Activities are prvided in several categries: Integrated Behaviral and Mental Health (BMH), Expanded Practice Access (EPA), Ppulatin Management (PM), Care Crdinatin (CC), Beneficiary Engagement (BE), Patient Safety and Practice Assessment (PSPA), Achieving Health Equity (AHE), and Emergency Respnse and Preparedness (ERP). The Appendix belw includes sme suggestins fr MIPS Imprvement Activities that may be particularly relevant t psychiatrists. In fact, there may be activities which yu (r yur practice) are already ding, n an nging basis, as a regular part f yur practice. What D I Need t Reprt? The general rule is that t receive full credit (100%, r 40 pints), mst psychiatrists will need t engage in at least tw high-weighted activities (wrth 20 pints each) r fur medium-weighted activities (wrth 10 pints each), r sme cmbinatin f thse. Onging activities must be dne fr at least 90 cntinuus days during the perfrmance year. Hwever, a psychiatrist nly needs t reprt n ne high-weighted r tw medium-weighted activities fr full credit (100% scre), r ne medium-weighted activity fr half credit (50% scre), if he r she is: Part f a small grup practice with 15 r fewer clinicians; Lcated in a rural area; Lcated in a gegraphic health prfessinal shrtage area (HPSA), r Is a nn-patient-facing clinician wh bills fr 100 r fewer patient-facing encunters during a 12-mnth perid. Fr a grup, mre than 75% f the clinicians with individual Natinal Prvider Identificatins (NPIs) billing under the grup s tax identificatin number (TIN) must meet the definitin f being nn-patient facing. Telepsychiatry (and ther telehealth) services are cnsidered patient-facing. Psychiatrists wh are part f a practice that is a certified patient-centered medical hme (PCMH), r cmparable specialty practice, will autmatically receive full credit fr this categry. At least 50% f the practice sites (physical lcatins) within the TIN must be recgnized a a patient-centered medical hme r cmparable specialty practice. Psychiatrists in ther types f MIPS alternative payment mdels, such as accuntable care rganizatins, may als receive credit in the Imprvement Activities categry. Hw D I Reprt? When D I Reprt? American Psychiatric Assciatin 2
Under the Imprvement Activities categry, yu r yur grup must attest t CMS with a Yes r N respnse n whether yu perfrmed the selected activities. This is the nly MIPS categry that invlves a simple attestatin. This can be submitted directly t CMS. Or, it can be submitted n yur behalf by yur health IT vendr, qualified clinical data registry (QCDR), r qualified registry. Grups f 25 r mre eligible clinicians have the additinal ptin t reprt via the CMS Web Interface. The deadline fr 2017 data submissin t CMS was April 3, 2018. Can I Earn MIPS ACI Credit fr Sme Imprvement Activities? If yu are capturing particular Imprvement Activities using Certified Electrnic Health Recrd Technlgy (CEHRT), yu may als qualify fr a bnus twards yur scre in the MIPS Advancing Care Infrmatin (ACI) perfrmance categry. These particular activities are indicated in the CMS resurces that list MIPS Imprvement Activities. RESOURCES Where can I find ther APA resurces? The APA Payment Refrm Tlkit is available at psychiatry.rg/paymentrefrm. Infrmatin abut the APA mental health registry, PsychPRO, is available at https://www.psychiatry.rg/psychiatrists/registry. What CMS resurces are available? CMS has many resurces n the Quality Payment Prgram website (https://qpp.cms.gv) including: QPP Resurce Library: https://www.cms.gv/medicare/quality-payment-prgram/resurce- Library/Resurce-library.html 2018 QPP Final Rule Overview Fact Sheet: https://www.cms.gv/medicare/quality- Payment-Prgram/Resurce-Library/QPP-Year-2-Final-Rule-Fact-Sheet.pdf 2018 QPP Final Rule Executive Summary: https://www.cms.gv/medicare/quality- Payment-Prgram/Resurce-Library/QPP-Year-2-Executive-Summary.pdf MIPS Imprvement Activity List (1/24/2018): https://www.cms.gv/medicare/quality- Payment-Prgram/Resurce-Library/2018-Imprvement-Activities.zip. MIPS Data Validatin Criteria (11/21/2017): The file fr Imprvement Activities lists the dcumentatin required fr each activity. https://www.cms.gv/medicare/quality- Payment-Prgram/Resurce-Library/2017-MIPS-Data-Validatin-Criteria-Quality-11-21- 17.zip American Psychiatric Assciatin 3
What if I still have questins? APA members may cnsult APA staff experts by sending an email t qualityandpayment@psych.rg, r by calling the Practice Management Helpline, at 1-800-343-4671. The CMS QPP Service Center accepts questins frm the public at QPP@cms.hhs.gv r 1-866- 288-8292. APPENDIX: SUGGESTED IMPROVEMENT ACTIVITIES FOR PSYCHIATRISTS Multiple Activities IA-EPA-1 IA-EPA-2 IA-PM-16 IA-CC-9 IA-PSPA-5 IA-PSPA-6 IA-PSPA-9 IA-PSPA-10 IA-AHE-1 IA-BMH-1 IA-BMH-4 IA-BMH-5 IA-BMH-7 Activities fr QCDR participatin: Mst are Medium. Includes participatin in PsychPRO. Learn mre at https://www.psychiatry.rg/psychiatrists/registry. Prvide 24/7 access t MIPS eligible clinicians r grups wh have real-time access t patient s medical recrd: High Use f telehealth services that expand practice access: Medium. Must include analysis f data fr quality imprvement. Implementatin f medicatin management practice imprvements: Medium Participatin in the CMS Transfrming Clinical Practice Initiative: Medium Annual registratin in the Prescriptin Drug Mnitring Prgram: Medium Cnsultatin f the Prescriptin Drug Mnitring Prgram: High Cmpletin f AMA Steps Frward prgram: Medium. Available at https://www.stepsfrward.rg/. APA is nt respnsible fr cntent r prcess. Cmpletin f training and receipt f apprved waiver fr prvisin f piid medicatin-assisted treatments: Medium. Must receive prescribing number. APA curse available thrugh APA Learning Center n www.psychiatry.rg. Engagement f new Medicaid patients and fllw-up: High Diabetes screening fr peple with schizphrenia r biplar disrder wh are using antipsychtic medicatins: Medium Depressin screening: Medium. Includes fllw-up plan fr patients with c-ccurring cnditins f behaviral r mental health cnditins. Majr Depressive Disrder (MDD) preventin and treatment interventins: Medium. Includes suicide risk assessment fr mental health patients with cccurring cnditins f behaviral r mental health cnditins. Implementatin f Integrated Patient Centered Behaviral Health Mdel: High. Integrated behaviral health services fr patients with behaviral health needs and prly cntrlled chrnic cnditins. American Psychiatric Assciatin 4
IA-BMH-9 Unhealthy alchl use fr patients with c-ccurring cnditins f mental health and substance abuse and ambulatry care patients: High American Psychiatric Assciatin 5