Isabella Carter
The Merit-based Incentive Payment System (MIPS) is a CMS program that tracks and rewards effective, outcomes-driven medical care. It combines three existing quality and value-reporting programs: PQRS, the Value-Based Modifier (VBM), and the EHR Meaningful Use (MU) program. MIPS scores are weighted across four categories: Quality, Promoting Interoperability (PI), Improvement Activities (IA), and Cost. For rehab therapists, successful MIPS participation requires understanding the differences between these categories and reporting on each. This includes knowing the data completeness requirements, which will be raised to 75% for the MIPS performance year (PY) 2024. For individuals, completing the Improvement Activities category involves performing the activity for 90 consecutive days during the PY, while for groups, at least 50% of NPIs must complete these activities for the full group to receive credit.
| Characteristics | Values |
|---|---|
| Name of the program | Merit-based Incentive Payment System (MIPS) |
| Participants | Rehab therapists, clinicians, individuals, groups |
| Purpose | To track and reward effective, outcomes-driven medical care |
| Categories | Quality Measures, Improvement Activities, Promoting Interoperability (PI), Cost |
| Quality Measures requirements | Reporting on 70% of all patients or 70% of the Medicare Part B patient pool |
| Improvement Activities requirements | Performing the activity for 90 days (individuals), 50% of NPIs in the reporting group (groups) |
| Non-patient facing practices | Radiology, pathology, R-SCAN projects |
| Brainstorming sessions | SWOT analyses, identifying strengths, weaknesses, opportunities, and threats |
| Final MIPS Score calculation | Quality Weighted Score (30%) + PI Weighted Score (25%) + IA Weighted Score (15%) + Cost Weighted Score (30%) + bonuses |
| Small practices | Exempt from utilizing a certified EHR for PI category reporting |
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What You'll Learn
Quality measures and improvement activities
The Merit-Based Incentive Payment System (MIPS) is a method for CMS to track and reward effective, outcomes-driven medical care. The program has been around since 2017 and has undergone several revisions. MIPS combines three existing quality and value-reporting programs: PQRS, the Value-Based Modifier (VBM), and the EHR Meaningful Use (MU) program.
For rehab therapists, the MIPS score is weighted among four categories: Quality Measures, Improvement Activities, Promoting Interoperability (PI), and Cost. Quality Measures and Improvement Activities are the two categories that rehab therapists are currently weighted on to determine their MIPS score.
Quality measures refer to the data that individuals and groups collect to evaluate their performance. For example, participants who use Medicare Part B claims to report quality measures must have measures available for 70% of the Medicare Part B patient pool being treated.
Improvement activities, on the other hand, are a newer category with a prophylactic approach. This category evaluates the ways in which clinicians and groups work to improve their practice over an extended period. This could include enhancing care coordination, expanding patient access, and improving patient-clinician decision-making. For individuals, successful completion of the Improvement Activities category requires performing the activity for a consecutive 90-day period during the performance year. For groups, at least 50% of the NPIs in the reporting group must complete these activities for the full group to receive credit.
Non-patient-facing practices, such as radiology and pathology, also have a responsibility to adopt improvement activities and transform their practices. For instance, participation in an R-SCAN project can help fulfill requirements for several Improvement Activities. Additionally, brainstorming sessions and SWOT analyses can be valuable tools for non-patient-facing providers to identify areas for improvement and innovate.
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Data completeness
It is important to note that the data completeness benchmark for the MIPS performance year 2024 has been raised to 75%, as per CMS's 2023 final rule. This means that participants need to report on a higher percentage of patients to meet the data completeness requirements.
For rehab therapists, the MIPS program has been in place since 2017. It was created as a mechanism for CMS to track and incentivize effective, outcomes-driven healthcare practices. The program undergoes frequent revisions to stay aligned with evolving healthcare standards and requirements.
To achieve their final MIPS score, rehab therapists must report on both the Quality Measures and Improvement Activities categories. The Improvement Activities category involves evaluating the long-term efforts of clinicians and groups to enhance their overall practice. This includes aspects such as improved care coordination, expanded patient access, and better patient-clinician decision-making.
Successful completion of the Improvement Activities category for individuals entails performing the activity consecutively for a 90-day period during the performance year. For groups, at least 50% of the NPIs in the reporting group must complete these activities to receive credit.
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Practice improvement
The Merit-Based Incentive Payment System (MIPS) is a method for CMS to track and reward effective, outcomes-driven medical care. MIPS improvement activities are a relatively new category with a prophylactic approach. The purpose of this category is to evaluate the ways in which clinicians and groups work to improve their practice as a whole over an extended period. This includes non-patient-facing practices, such as radiology and pathology, which have a responsibility to learn and adopt the skill set needed to improve and transform their practices.
For non-patient-facing providers, attesting to improvement activities under MIPS can be challenging. For example, radiology practices may benefit from peer-based assistance in practice transformation and should consider registration and participation in R-SCAN, which can fulfill requirements for up to seven improvement activities.
Additionally, brainstorming sessions are an important part of the quality improvement process. While not often considered a formal piece of the process, brainstorming is essential for innovation and determining new interventions to combat existing barriers or issues. SWOT analyses are another useful tool, allowing a department or organization to identify major internal and external barriers and opportunities for improvement. By encouraging stakeholders to identify internal strengths and weaknesses, as well as external threats and opportunities, groups can not only improve practices but also formulate a strong strategic plan.
For individuals participating in MIPS, successful completion of the Improvement Activities category requires performing the activity for a consecutive 90-day period during the performance year. For groups, at least 50% of the NPIs in the reporting group must complete these activities for the full group to receive credit.
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Brainstorming sessions
Establish an agenda and shared understanding
Before the session, it is important to outline the topic, parameters, scope, and any key terms. This ensures that everyone invited to the brainstorming session has a shared understanding of the problem and the goals. This will help to make the session more productive.
Create a safe and open environment
To encourage participants to share their ideas freely, it is important to create an environment of psychological safety. This means ensuring that all ideas are welcomed and that criticism, argument, or negativism is eliminated. Participants should be reminded that the goal is to generate a large quantity of ideas, and that all ideas are valuable, no matter how outlandish.
Encourage participation
Brainstorming is a team activity, so it is important to get everyone involved. Use techniques such as a round-robin approach, where each participant contributes one idea at a time, to ensure everyone has a chance to speak. However, do not force contributions—allow individuals to pass if they wish.
Focus on questions, not answers
Rather than brainstorming answers, focus on questions. This helps to avoid group dynamics that can stifle voices and allows for a reframing of problems, often leading to breakthrough thinking. For example, give the group a problem to consider, and ask them to generate as many questions about that problem as they can in a short space of time.
Build on each other's ideas
Encourage participants to build on and expand the ideas of their colleagues. This can help to generate even more possibilities and can lead to innovative solutions.
By following these tips, you can run effective brainstorming sessions that contribute to quality improvement activities and help to enhance care coordination, expand patient access, and improve patient-clinician decision-making.
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R-SCAN projects
R-SCAN, or Radiology Support Communication and Alignment Network, is a CMS-selected initiative that helps radiologists and their referring physician colleagues reduce unnecessary testing and procedures. The ACR Radiology Support Communication and Alignment Network was awarded $2.9 million in 2015 to support the transformation of physician practices toward value-based reimbursement through R-SCAN. This funding would ultimately support nearly 140,000 clinician practices in their efforts to expand quality improvement, engage in shared learning, and leverage health data to boost performance.
For successful completion of the Improvement Activities category, individuals must perform the activity for a consecutive 90-day period during the performance year. Groups require at least 50% participation to receive credit. R-SCAN projects can be paired with other department initiatives, such as the Emergency Quality Network, to enhance radiology-specific quality improvement projects.
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Frequently asked questions
MIPS stands for Merit-based Incentive Payment System. It combines 3 existing quality and value-reporting programs into one: PQRS; the Value-Based Modifier (VBM); and the EHR Meaningful Use (MU) program.
MIPS applies to eligible clinicians and groups. For individuals and groups who use QCDR, MIPS CQMs, and eCQMs to collect their quality measures, they must report on 70% of all patients.
The MIPS categories are Quality Measures, Improvement Activities, Promoting Interoperability (PI), and Cost.
Improvement Activities are a way to evaluate how clinicians and groups work to improve their practice over time. This includes enhancing care coordination, expanding patient access, and improving patient-clinician decision-making.
If you are participating as an individual, you must perform the Improvement Activity for a consecutive 90-day period during the performance year. If you are part of a group, at least 50% of the NPIs in the reporting group must complete the activities for the full group to receive credit.
