I know you love reading about the Merit Based Incentive Payment System (MIPS) as much as I love writing about it… However, MIPS now matters to a lot more practitioners as wound care transitions into the office-based/mobile setting. (I will make a mental note to post a blog about all the stupid stuff I would fix in MIPS if I were Queen). MIPS has 4 components: Quality, Improvement Activities (IAs), Promoting Interoperability (PI) and Cost. Theoretically, Quality, IA and PI are under the control of the clinician. I have written the most about Quality and not said much about Improvement Activities. I will spare you the calculus about how important IAs can be to the MIPS final score, but depending on a lot of variables (e.g., whether there is a Cost measure that applies to the clinician, whether they are exempt from PI), IAs can count for fully half of the final MIPS score.
I’ve spent a decade trying to come up with Improvement Activities that actually mattered in wound care. I came up with “brilliant” ideas like improving your rate of applying adequate compression to VLUs, improving your rate of providing adequate DFU off-loading, improving your rate of arterial assessment, and improving nutritional screening. Those seem like things that would make a real difference to the outcome of our patients. However, over the past several years, the IAs recommended by the Centers for Medicare & Medicaid Services (CMS) stopped feeling relevant. Now the wind has changed. CMS has suspended 8 improvement activities for MIPS, as of May 6.
The eight suspended improvement activities are:
- MIPS Eligible Clinician Leadership in Clinical Trials or Community-Based Participatory Research;
- COVID-19 Clinical Data Reporting with or without Clinical Trial;
- Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
- Practice Improvements that Engage Community Resources to Address Drivers of Health;
- Use of Toolsets or Other Resources to Close Health and Health Care Inequities Across Communities;
- Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols;
- Create and Implement an Anti-Racist Plan; and
- Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients.
I only have issue with #6. The US Wound Registry (USWR) recommended that activity for patients with chronic wounds and clinicians have actually paid attention to it. The rate of nutritional screening for patients with chronic wounds/ulcer has been going up and the data are scary. Lots of patients with chronic ulcers (maybe more than half) are either malnourished or at risk of malnutrition. You can still continue to perform nutritional screening and making supplement recommendations as an IA through participation in the USWR Qualified Clinical Data Registry.
If you already performed one of the IAs listed this year, you will still be able to attest to completing them and receive credit. If you haven’t initiated any of these eight improvement activities after May 6 (as part of the 90-day reporting period), then you should select from the remaining 96 on the traditional MIPS list to meet requirements for the improvement activities performance category.
The QPP website also explains that in 2025, improvement activities won’t be classified as medium-weight or high-weight as they were in previous years, streamlining what’s required to receive full credit in this performance category. Now, per QPP’s guidance for reporting improvement activities, small practices, rural and non-patient facing clinicians only need ONE IA. Everyone else needs two, but they are all worth the same number of points. At least one thing about scoring got easier.
Caroline
Resources:
Dr. Fife is a world renowned wound care physician dedicated to improving patient outcomes through quality driven care. Please visit my blog at CarolineFifeMD.com and my Youtube channel at https://www.youtube.com/c/carolinefifemd/videos
The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.
