• MIPS 2019—Improvement Activities: An Overview

    This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page


    Improvement activities is one of four performance categories that can contribute to your MIPS final score.

    The improvement activities performance category is weighted at 15% of your MIPS final score. It can contribute up to 15 points to your MIPS final score (0-100 points).

    Performance period. You must perform improvement activities for a performance period of at least 90 consecutive days during the current calendar year (Jan. 31, 2019 to Dec. 31, 2019).

    The improvement activities performance category remains largely the same as in 2018. However, you should note that you can report 10 additional improvement activities via the IRIS Registry (see Table 13: Improvement Activities at a Glance), including one improvement activity that involves provision of free eye exams.

    Warning! An improvement activities performance category score of 100% is no longer enough to help you avoid the payment penalty. As in 2018, if you score 100% for improvement activities, you will earn 15 points toward your 2019 MIPS final score. Last year, that would have been enough to avoid a future MIPS payment penalty, but that is not the case in 2019. Because the threshold for avoiding penalty has increased to a MIPS final score of 30 points, you also should perform quality measures and/or promoting interoperability (PI) measures.

    How You’ll Be Scored

    Scoring for this performance category is the same as in 2018. To max out your score, you will need to successfully perform one to four performance activities—the amount that you need to perform depends on how those activities are weighted, as well as the size and location of your practice. You need to perform each activity for at least 90 consecutive days.

    How many points do you get for an improvement activity? This depends on 1) how the activity is weighted and 2) whether you’re able to double the score.

    If an activity’s weight is:

    • medium—it scores 10 points (double score is 20 points)
    • high—it scores 20 points (double score is 40 points)

    Who scores double? MIPS participants can score double for an improvement activity if they have one of these special statuses:

    • small practice (fewer than 16 eligible clinicians during the MIPS determination period),
    • rural practice (according to an update published by CMS on Aug. 14, 2019, ZIP codes will be considered rural based on the most recent Federal Office of Rural Health Policy eligible ZIP codes, not the HRSA Area Health Resource File data set),
    • practice that is in a geographic health professional shortage area (HPSA), or
    • non–patient-facing MIPS clinicians.

    Are you a non–patient-facing clinician? Probably not. Few ophthalmologists are likely to fall within this category. You are designated a non–patient-facing MIPS clinician if you bill Medicare for no more than 100 patient-facing encounter codes—including Medicare telehealth services—in a designated period.

    Check whether CMS doubles your score. To see if you fall within one of the special status categories, use the CMS Participation Lookup tool. After entering your 10-digit National Provider Identifier (NPI), scroll down to “Other Factors.” If you are in more than one practice, make sure you scroll through your whole record, so you can see your status for each practice.

    Maximum score is capped at 40 points. If you don’t have a special status that doubles your score, you can accrue the maximum score of 40 points by performing either:

    • two high-weighted activities (2 × 20 points)
    • two medium-weighted activities (2 × 10 points) and one high-weighted activity (1 × 20 points), or
    • four medium-weighted activities (4 × 10 points).

    If you are eligible to score double, you can accrue 40 points by performing:

    • one high-weighted activity (1 × 40 points) or
    • two medium-weighted activities (2 × 20 points).

    (Note: Because the improvement activities performance category is weighted at 15% of your MIPS final score, a maximum improvement activities score of 40 points would contribute 15 points to your MIPS final score.)

    Each improvement activity is all or nothing. You won’t score points for an improvement activity unless it is performed for 90 consecutive days and you satisfy all of its requirements. You do not score partial credit for reporting a partially performed activity.

    Some MIPS participants will automatically get credit. MIPS eligible clinicians (and groups) who are practicing as part of an accredited patient-centered medical home (or comparable specialty practice) will automatically score 40 points (the maximum score); those who are participating as part of an advanced alternative payment model (APM) will automatically score a minimum of 20 points (half the maximum score). Few ophthalmologists are expected to fall within these two categories in 2019.

    Your improvement activities score (0-40 points) is turned into a percentage, which contributes up to 15 points to your MIPS final score. CMS divides your total number of points by 40 and turns the resulting fraction into a percentage (e.g., a score of 40 points would be 100%). This contributes up to 15 points to your MIPS final score (e.g., a score of 100% would contribute 15 points).

    Improvement activities no longer provide a PI bonus. In 2017 and 2018, certain improvement activities would earn you a PI bonus if CEHRT was used to help you perform those activities. This is no longer the case in 2019.

    Previous: Table 12: Promoting Interoperability's New Scoring Methodology (Example)

    Next: Improvement Activities: Decide How You Will Report

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