MIPS Proposed Rule 2022: Improvement Activities

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The Improvement Activities category is not proposed to change dramatically in the 2022 performance year. The category will continue to count as 15% of the total MIPS score. If you do not report an activity from the inventory list for the minimum number of days, you will receive 0 points for the category. Many practices are already doing the activities, and so should take advantage of getting these points. Most clinicians must implement and attest to 2 to 4 improvement activities to receive the maximum 40 points.

CMS has also made proposals to consider criteria for nominated activities.  Many of these will not affect a practice.

Group Reporting: CMS is proposing to revise group reporting requirements to address subgroups (like in APPs or upcoming MVPs).  In 2022, each Improvement Activity that is attested with a yes answer, CMS is proposing that at least 50% of the NPIs billing under the TIN of the sub-group, must perform the same activity during the same continuous 90-day period.

Removal of Activities: CMS is creating a rule to suspend an activity during the year that may raise patient safety concerns, rather than wait until the next rule-making period.

Activities Inventory:  CMS is proposing to add seven new improvement activities, three related to promoting health equity; modify 15 current activities, 11 related to health equity; and removed six previously adopted improvement activities.  Practices are encouraged to review their current activities (reported in prior years) before the end of the year to ensure it is still active.  There are usually over 100 activities to report on.

The information was presented in a webinar in September 2021. 
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