Understanding the MIPS Improvement Activities Category in 2023

This page will cover changes and updates to the MIPS Improvement Activities category in the 2023. For the 2023 Performance Year, CMS has removed six activities, modified five, and added four new activities that focus on health equity initiatives.

Readers of the Final Rule will find no significant policy changes regarding Improvement Activities. Still, starting this overview with a renewed look at the rationale for the Improvement Activities category may be helpful.

MIPS Improvement Activities: The Category Explained

An Improvement Activity is an activity that CMS expects will improve clinical practice or care delivery. Activities, when effectively executed, are anticipated to result in improved patient outcomes.

The Improvement Activities category represents 15% of your final MIPS score under the traditional MIPS scoring scenario. To earn full credit for IA, you generally need to submit one of the following combinations of activities:

  • Two high-weighted activities
  • One high-weighted activity and two medium-weighted activities
  • Or four medium-weighted activities

Small Practices (those with 15 or fewer clinicians) receive full credit when you perform and attest to:

  • One high-weighted activity, OR
  • Two medium-weighted activities

Individual clinicians and groups with a qualifying special status of Non-patient Facing, Small Practice, HPSA, and Rural will receive double points for activities submitted.

In 2023, CMS has updated the performance category redistribution policies for small practices only to more heavily weight the improvement activities performance category when other performance categories are reweighted.

Standard weighting for small practices, because Promoting Interoperability is automatically reweighted, has Improvement Activities weighted at 30%, Quality at 40% and Cost at 30%.  See page 12 in this PDF for additional information: MIPS 2023: What’s new for Small Practices

Individual clinicians and groups with a qualifying special status of Non-patient Facing, Small Practice, HPSA, and Rural will receive double points for activities submitted.

You can explore Improvement Activities using this tool on the Quality Payment Program website >>

Changes to Improvement Activities in the 2023 Final Rule

In the 2023 Final Rule, there were no policy changes to the category – such as criteria used to evaluate proposed Activities, or to global edits like we saw in 2021. The category will operate the same way as in the previous year.

There were, however, changes to the inventory of Improvement Activities that MIPS participants can submit for the 2023 Performance Year. You’ll find a detailed explanation of changes to the IA inventory below, but here’s a general list of updates in the 2023 Final Rule:

  • Four Improvement Activities were added for 2023
  • Five Improvement Activities were modified for 2023
  • And six Improvement Activities were removed for 2023
Improvement Activity Additions in the 2023 Final Rule

CMS has added four new Improvement Activities for the 2023 Performance Year in the Final Rule. These new activities fill gaps in the Inventory and are in response to both the Biden administration’s emphasis on health equity and Executive Order 13985: “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government”

Additionally, CMS has released the Framework for Health Equity 2022-2032 that set a path forward to advance health equity, expand coverage, and improve health outcomes for individuals supported by CMS programs.

The CMS Framework for Health Equity includes five priorities to reduce health disparities. The five priorities are:

  • Priority 1: Expand the Collection, Reporting, and Analysis of Standardized Data
  • Priority 2: Assess Causes of Disparities Within CMS Programs and Address Inequities in Policies and Operations to Close Gaps
  • Priority 3: Build Capacity of Health Care Organizations and the Workforce to Reduce Health and Health Care Disparities
  • Priority 4: Advance Language Access, Health Literacy, and the Provision of Culturally Tailored Services
  • Priority 5: Increase All Forms of Accessibility to Health Care Services and Coverage

In the 2023 Final Rule, CMS used this framework in creating the four new Improvement Activities available to MIPS participants in the coming year. The new Improvement Activities are:

  • IA_AHE_10: “Adopt Certified Health Information Technology for Security Tags for Electronic Heath Record Data” – Medium weight
  • IA_ERP_6: “COVID-19 Vaccine Achievement for Practice Staff” – Medium weight
  • IA_AHE_11: “Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients” – High weight
  • IA_EPA_6: “Create and Implement a Language Access Plan” – High weight
Modified Activities in the 2023 Final Rule

Five Improvement Activities were modified in the 2023 Final Rule. Here’s a list of each adjusted activity, followed by a short description of the changes made:

Activity ID Activity Name Changes
IA_PSPA_7 “Use of QCDR data for ongoing practice assessment and improvements” Consolidation of different Improvement Activities (IA_BE_7, IA_BE_8, and IA_PM_7) into this single activity.
IA_PSPA_19 “Implementation of formal quality improvement methods, practice changes, or other practice improvement processes” Consolidation of another activity (PSPA_20) into this activity by including leadership in addition to staff in quality improvement activities.
IA_PSPA_10

Recategorized to IA_BMH_13

“Obtain or Renew an Approved Waiver for Provision of Buprenorphine as Medication-Assisted Treatment of Opioid Use Disorder” Incorporation of HHS Guidelines for Administration of Buprenorphine for Treating Opioid Use Disorder and removal of the 8-hour training requirement for physicians.
IA_CC_14

Recategorized to IA_AHE_12, changed title.

“Practice Improvements that Engage Community Resources to Address Drivers of Health” “Drivers of Health” will replace “Social Determinants of Health (SDOH)” and “Health-Related Social Needs” (HRSN),” broadens the list of factors for Drivers of Health (DOH)
IA_CC_13

Changed title.

“Practice Improvements to Align with OpenNotes Principles” Advancing the concept of OpenNotes to promote direct clinician-to-patient communication.
Removed Activities in the 2023 Final Rule

CMS removed six activities for the 2023 Performance Year in the Final Rule. Most of these activities were removed for being duplicative and were consolidated into existing Improvement Activities.

CMS removed one Improvement Activity due to obsolescence – the PCI Bleeding Campaign activity. This campaign ended in August of 2021, so the activity has been removed for future Performance Years.

One Improvement Activity removal that may affect many MIPS participants: “Consultation of the Prescription Drug Monitoring program” – this activity has been removed for the 2023 Performance Year.

CMS removed this Improvement Activity as it was duplicative of a new measure – “Query of PDMP” – in the Promoting Interoperability performance category. This will impact many practices because it was a frequently used, high weighted activity. If you’ve attested to the “Consultation of the Prescription Drug Monitoring program” Improvement Activity in previous years, you’ll have to make alternative plans for 2023.

Mingle Health is here to help.

Have additional questions or concerns about the MIPS Improvement Activities Category in 2023? Get in touch with one of our experts today to learn more about MIPS, understand how you can improve your organization’s performance, and set yourself up for success in the coming years.

Click here to return to the 2023 MIPS Success Guide >>