Basics and Participation Requirements MIPS 2021 Reporting

Whst is MIPS?

MIPS or the Merit-based Incentive Payment System is one of the two tracks that come under the Quality Payment Program (QPP). It is a program that moves the Medicare part B providers to a performance-based payment system.

It streamlined three old Medicare programs into one and introduced categories instead. Based on them, medical practitioners are awarded a score called the MIPS composite or final score.

These categories are,

1. Quality
2. Improvement Activities (IA)
3. Promoting Interoperability (PI)
4. Cost

All categories have different regulations and hold a percentage of the final score, which can be changed or updated annually.

In MIPS 2021, the score has been divided among them in the following way.

1. Quality – 40%
2. Improvement Activities (IA) – 15%
3. Promoting Interoperability (PI) – 25%
4. Cost – 20%

Today we will be focusing on the Improvement Activities (IA) category, its basics, and which of its requirements clinicians need to fulfill this year.

Improvement Activities (IA)

This category assesses participation in activities that support and improve the medical practice’s services, care delivery, and patient outcomes. 

There are more than 100 activities to choose from in MIPS 2021 IA, so it won’t be hard to find something that suits you and your practice.

Subcategories of Activities

All of the activities are divided into 8 subcategories.

1. Expanded Practice Access
2. Population Management
3. Care Coordination
4. Beneficiary Engagement
5. Patient Safety and practice assessment
6. Achieving Health Equity
7. Emergency Preparedness and Response
8. Integrated Behavioral and Mental Health

Overview

Every year, the weightage of each main MIPS performance category changes or gets updated. In 2021, this category makes up 15% of the MIPS composite or final score. Participants can choose 2 to 4 activities at most, as the maximum score for this category is 15. 

All the chosen activities should be performed for a consecutive 90-day period, and the data regarding them, in the form of MIPS Quality Measures, has to be recorded. When it ends, you have to submit your reports and attest to the activities you performed.

Determination of Improvement Activities for the Year 2021 

Each year, the activities in the improvement category are reviewed. It allows them to be modified and for new activities to be suggested or added into the mix.

It happens at an annual meeting, where the stakeholders, including clinicians, researchers, professionals from health organizations, consumer groups, etc. submit new types of improvement activities or suggest modifications for an already existing one.

Usually, the nominations submitted from February to June are considered for the following calendar year, but they are not implemented immediately. Instead, they are applied two years later, while the submissions made in July or afterward are for future years.

As an example, the activities submitted for MIPS 2021 quality reporting will most likely be implemented in 2023, and the rules for them will be published in 2022.

Changes in 2021

There are only a few changes made to the improvement category this year.

1. CMS continues with the high-weighted COVID-19 Clinical Data Reporting with or without Clinical Trial (IA_ERP_3) improvement activity in 2021. 
2. 2 existing improvement activities were modified.
3. Engagement of Patient through Implementation of Improvements in Patient Portal (IA_BE_4) – This modification allows caregivers to be potential users of the patient portal. It is because they play a vital role in information exchange when it comes to the clinical care of patients.

It also added language, which clarified that the portal’s primary use should be clinical and not administrative for MIPS 2021.

• Comprehensive Eye Exams (IA_AHE_7) – This modification added language that expands the types of services that eligible clinicians can promote to underserved and high-risk populations to receive credit for this activity.

• One activity was removed because it is obsolete and can no longer be reported, which is the CMS Partner in Patients Hospital Engagement Network (IA_CC_5).

Choosing the Activity

There are no set rules for the selection of activities for IA MIPS 2021 reporting other than their number. Clinicians don’t have to choose activities from each subcategory or a select number of categories. 

Instead, the main focus should be on selecting activities that are best for their practice and support their patient’s needs by improving patient care.

If you want to, you can choose activities from a single subcategory. Or go through the entire list if you are unsure which is the best, as it will help clarify things.

Activities can also be renamed going through the MIPS 2021 data submission process, so be careful and keep a sharp eye while looking as you might have done them before. The list can be narrowed down by dividing the activities according to levels.

For this, you can use the “Explore and Measures and Activities Tool”. It helps search for activities that align with your selected performance category through the use of keywords. Or, simply you can consult a MIPS Qualified Registry for seamless data submission. However, don’t forget to read the descriptions of each carefully to gauge if they suit you or not.

Participants and Reporting Types

The participants we see in MIPS can be divided into 4 types.

• Individuals
• Groups
• Virtual Groups
• APM Entities

All have to perform the activities for the allotted period of 90 continuous days and submit their reports. If you are planning to report as a group, a virtual group, or as an APM entity, then at least 50% of the clinicians in your group will have to implement the same activity in the same performance year for the specified activity period. 

Do keep in mind, you don’t need to do them together, just for 90 continuous days at any time in the performance year.

Only this way can the group successfully attest to their activities and participation.

Special Status Designations

Special status designations make things a little easier for the participants that qualify for them. There are different designations for different types of participants, and those who fit the bill need to submit only 1 to 2 activities instead of the regularly required 2 to 4. 

Clinicians eligible for these designations are mostly part of a patient-centered medical home, comparable specialty practice, or a MIPS 2021 APM.

Now they are required to do lesser activities because normally, there are two categories of activities by weight; medium-level and high-level. 

Most medium-level activities are worth 10 points, and high-level activities are worth 20 points.

But special designations increase the points of each category. Medium-level activities become worth 20 points each, and high-level activities become worth 40 points each. So even if 1 or 2 activities are performed, the participant can attest because their score adds up to the required 40 points for the MIPS evaluation.

To check for special designations assigned at different levels, ask your third-party vendor MIPS Qualified Registry to provide you with all the information.