CMS Posts Report on MIPS Improvement Activities for Year 1 of the QPP

June 12, 2018


The Centers for Medicare and Medicaid Services (CMS) released a report on the Improvement Activities (IAs) Performance Category of the Merit-based Incentive Payment System (MIPS) for Year 1 of the Quality Payment Program (QPP). A Technical Expert Panel (TEP) was convened by CMS to review 93 IAs. These specific IAs were selected because the QPP Service Center had received inquiries on them.


In addition to the review of specific IAs, TEP members also provided some general feedback to CMS in the IA Performance Category.

  • IAs generally met their intent, and there were IAs to which both specialists and primary care providers could attest
  • No sense of real duplication in the IAs, although some TEP members thought that the IAs seemed to overlap in many areas, especially surrounding QCDR measures
  • Many TEP members voiced their approval of CMS’ alignment of IAs with the Advancing Care Information (ACI) through bonus points for some IAs
  • General consensus that the 90-day period for performance of IAs was appropriate, but some encouraged CMS to consider lengthening the period in the future
  • Many TEP members agreed that providers tend to be detail-oriented and would benefit from further documentation and guidance around what attestation to the different IAs require
  • IAs would benefit from additional organization; however, they were split on what this should entail
  • Consensus around the need for technological flexibility to reduce barriers for data collection
  • Felt positively about the IAs and their intent, but many highlighted the need for more engagement from CMS with providers so that practices and providers better understand the intent of IAs


The report is available here.

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