Medical RAC Audits Reviewed by Statistician Frank Cohen Medical RAC Audits Reviewed by Statistician Frank Cohen

MIPS: Explaining Clinical Practice Improvement Activities

The first-ever reporting period for the Merit-based Incentive Payment System (MIPS) is now in full swing, but one of the program’s core components remains mysterious. “Clinical improvement activities” or CPIA is one of the four MIPS components, and it may be the most crucial component in 2017.

This year has been designated as a MIPS “transition year” by CMS, which means among other things that of the four MIPS components, only three will count toward your overall MIPS score. That score will be used to determine whether your providers will receive payment bonuses, penalties, or no change for 2019, the MIPS payment year that 2017 performance will affect. CPIA is one of the three categories that will count.

The “Cost Performance” category of MIPS will not count toward your score in 2017, though CMS will still calculate your cost score and share it with you. Of those three components that count, CPIA is the most intriguing. The other components are “Quality performance” which is nearly identical to quality reporting under the Physician Quality Reporting System (PQRS), and “Advancing care information” which is the counterpart to the EHR meaningful use reporting program.

These are well understood by practices, being derived from PQRS and meaningful use, both of which the industry has been dealing with for many years.

What is CPIA?

Clinical practice improvement is not new either, but under MIPS it has grown to encompass 92 possible improvement activities. Some, such as “diabetes screening” and “depression screening,” are more relevant to primary care than specialties. But there are a wide variety of CPIA measures to choose from, including measures that are deliberately not specialty-specific.

The 92 total activities are split into nine different subcategories, as follows:

  • Expanded practice access
  • Population management
  • Care coordination
  • Beneficiary engagement
  • Patient safety and practice assessment
  • Participation in an Alternative Payment Model (APM)
  • Achieving health equity
  • Emergency preparedness and response
  • Integrated behavioral and mental health

You may choose activities from any of the categories. Because 2017 is a transition year, the bare minimum to satisfy MIPS reporting and avoid a payment penalty in 2019 is performing a single CPIA and reporting it. You could also get away with reporting one quality measure to guarantee a flat update in 2019.

It’s important to remember that MIPS is scored on a point system rather than a simple pass/fail metric for each component. Even for 2019, the first payment year, your providers will receive a MIPS composite score that is a number from 0 to 100.

Two weights: CPIAs are not all equal

One fact about CPIAs that has received little attention amid all the MIPS guidance and preparation is that not all measures are worth the same. CPIA measures are weighted differently by CMS. The agency maintains an interactive list of all CPIA measures with detailed descriptions online here.

Most CPIA measures have “medium” weight and are worth 10 points. Fourteen of the 92 total CPIA measures have “high” weight and are worth 20 points. These points do not directly translate to the MIPS composite score, but are instead added to a total CPIA point bank. That bank is then used to calculate your MIPS composite score together with points from the other MIPS categories. In a regular, non-transition MIPS year, CPIA is worth a maximum of 60 points, which can be arrived at with any combination of medium and high-weight measures.

The following CPIA measures have high weight (20 points). Bold measures stand out as being the most widely accessible regardless of your providers’ specialties. CMS offers a definition of each measure below, which you can read in full on the agency’s CPIA measure site.

  • Anticoagulant management improvements
  • Collection and follow-up on patient experience and satisfaction data
  • Consultation of the Prescription Drug Monitoring program. Defined by CMS as the “collection and follow-up on patient experience and satisfaction data on beneficiary engagement, including development of improvement plan.”
  • Engagement of new Medicaid patients and follow-up. Defined by CMS as “seeing new and follow-up Medicaid patients in a timely manner, including individuals dually eligible for Medicaid and Medicare.”
  • Glycemic management services
  • Implementation of co-location PCP (primary care) and MH (mental health) services
  • Implementation of integrated PCBH (primary care behavioral health) model
  • Participation in a 60-day or greater effort to support domestic or international humanitarian needs
  • Participation in CAHPS or other supplemental questionnaire
  • Participation in systematic anticoagulation program
  • Provide 24/7 access to eligible clinicians or groups who have real-time access to patient’s medical record. Defined by CMS as making sure all MIPS-eligible clinicians and entities have 24/7 access to your provider’s records for a patient, so that any urgent or emergent care issues can be handled.
  • RHC (rural health center), IHS (Indian health services) or FQHC (federally qualified health center) quality improvement activities
  • TCPI (Transforming Clinical Practice Initiative) participation
  • Use of QCDR (qualified clinical data registry) for feedback reports that incorporate population health

Documenting and scoring CPIA

CMS hasn’t released much explicit guidance on what type of documentation a provider would be required to maintain to prove that a CPIA measure was actually reported accurately. However, some practices aren’t being deterred and have found their own ways to document CPIA compliance (see related story, pg.. 5) CPIA measures can be reported via multiple methods, including via data registry. Regardless of reporting method, each participating provider must attest that they completed the CPIA measure.

Of the maximum possible CPIA score of 60 points, 40 points will be required to satisfy MIPS reporting in a regular, non-transition year (i.e. 2019 and beyond). The CPIA category can contribute a total of 15 points to your overall MIPS composite score (being weighted at 15% of the score). Therefore if a provider earns 60 CPIA points, that provider is guaranteed to receive a minimum MIPS composite score of 15 points, from CPIA alone. CMS may decide to increase or decrease the weight of CPIA towards the overall MIPS score in future years.