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where we cover interesting and relevant news, insights, events, and more related to the health care industry and pMD. Most importantly, this blog is a fun, engaging way to learn about developments in an ever-changing field that is heavily influenced by technology.


I recently celebrated my 10-year anniversary at pMD. 10 years at the same company is becoming a rarity in the software industry. Yet my dad, Dan Kenney, worked for 40 years for the same architecture firm. 40 years! It sounds like an old-timey tale, a story about the Company Man. I began to wonder what about his company could have possibly held his attention for so long - it must have been quite an amazing institution.

But many others at his company came and went over the years, so maybe it was him rather than the company itself. Did he lack imagination? He’d been very successful and could have retired earlier, yet he kept chugging away and taking on greater responsibilities. I think he was genuinely happy there, and he didn’t feel a need or desire to move.

I began to wonder if the anomaly is not him or his company, but rather the software industry. It began to seem strange that Amazon has a 1-year median tenure and Google has a 1.1-year median tenure, both in the bottom 5 of the Fortune 500 according to PayScale for this measurement. If these companies are admired and successful, why aren’t their employees sticking around?

There are many good reasons to leave a company. The top reason given is greater opportunity for career advancement elsewhere. In other words, there is a lack of mentorship and growth at the old company. Now, the same companies that failed to offer in-place growth opportunities are adapting to their job-hopping employees:

"Hiring managers worry they’ll become the next victims of these applicants' hit-and-run job holding. For companies, losing an employee after a year means wasting precious time and resources on training & development, only to lose the employee before that investment pays off.” - Jeanne Meister, Forbes


But by reducing training and mentorship, wouldn’t they further decrease the opportunity for in-place career growth? They aren't expecting employees to stay around for a long time, so they’re not investing in their people, instead focusing on making their jobs more specific and interchangeable - like a “code factory” where a new assembly line worker can easily be slotted into a vacant position.

I don’t know whether companies or employees started this vicious cycle, and perhaps it makes sense in an increasingly commoditized industry that is dominated by a few huge near-monopolies. And I’ve met my share of counter-examples even at these companies, “lifers” who have stuck around for a long time and have no intention to leave. So there’s a ray of hope: if the fit is right, and the position has room to grow, then career bliss can still occur - even in today’s bleak landscape. So then, how to find the right long-term fit for you?

While researching this question, I found many different answers. A romantic advice blog said it best:

“When you know what you want, everything else becomes trivial. The better you understand yourself, the more experience you have and the clearer the life you want becomes. When we learn more and more about ourselves throughout our lifetimes, we come to a point of clarity. We come to a point at which we know what we want, and we know what we have to do to get it.”


I think self-knowledge was the key to my dad’s 40-year happy place. He knew what he wanted to achieve in his career and what kind of culture he needed to be successful, and he worked ceaselessly towards both. He didn’t bail when times got tough because he knew what he wanted, and he knew that his company was the right place where he could forge that vision into reality regardless of any setbacks along the way.


Dan Kenney

Self-knowledge sounds great. If only they sold it on Amazon! Some people seem to be “old souls,” born with more of it. Unfortunately for the rest of us, it’s generally hard-won. Most people gain self-knowledge by making mistakes and learning from those mistakes. Indeed, embracing failure is the approach most commonly recommended in tech. This is a very effective way to learn, but not a very efficient way because there are so many possible mistakes. Even if you learn from each mistake that you make, there are countless other varieties just around the next corner lying in wait for you. You’ll never live long enough to make all the mistakes.

Fortunately, you can also gain self-knowledge in other ways. You can ask experienced and successful people for advice, or read books written by wise people, and benefit from their mistakes without having to make the same mistakes yourself. You can pursue meditation or counseling to gain greater awareness of your own biases, blind spots, and true desires.

For example, would you enjoy the rollercoaster ride of a high-risk company such as an early-stage startup, or would you prefer the sanity and routine of a company that’s been around for a while? Would you appreciate the well-defined, relatively narrow expectations of a career at a large company, or would you prefer the freedom, flexibility, and variety of a small company? Is it most important to you to feel protected and cared for by a high-comfort company, or are you happiest when making sacrifices for the good of others at a high-service company such as a nonprofit?

In the end, it’s all about what you want and what makes you happy and satisfied. If you know what your sweet spot would look like and you put all your energy into finding or creating it, then all the other decisions along the way become trivial and you’re on your way to the mythical 40-year, same-company career. I hope to see you there!

Interested in joining the pMD team? Check out pMD's careers page for more information! To find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

Image: Tony Cenicola/The New York Times

Here's The Latest in Health Care:


•  Recent data released by the Centers for Medicare and Medicaid Services revealed that providers who stuck with accountable care organization (ACO) models are starting to see success in savings. One shining example is the ACO for NYC Health + Hospitals. They have reduced costs to Medicare by more than $31 million, generated $14 million in shared savings payments, and are providing other organizations with lessons in fostering leadership in ACOs.  Read More

•  Skin on fruits and veggies don't always form an impermeable barrier when it comes to pesticides.  Depending on the pesticide, it can either sit on the outer peel or can be designed to absorb into the tissue of the fruit or vegetable to keep out bugs that penetrate the skin. Do your research when it comes to deciding which fruits and veggies are necessary to buy organic!  Read More

•  On Wednesday, the Congressional Budget Office released an analysis of the current individual health insurance mandate. According to the report, getting rid of this requirement, which states that everyone in the country should have health insurance coverage, would save the government $338 billion over the next decade. However, the savings would come at the expense of more than 13 million individuals who will no longer have insurance coverage by 2027.  Read More

•  The National Institutes of Health's (NIH) All of Us Research Program will be using Fitbit devices for a longitudinal study aiming to collect data and gain insight on the characteristics of more than a million Americans.  The data being collected for this one-year study includes physical activity, heart rate, sleep, and other health outcomes.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

In March of 2016, I was thrilled to learn I’d be joining the pMD team. The interview process was challenging but rewarding, and I couldn’t wait to learn from all of the incredible people I had met throughout the process. After about a month into my new role, I received even more exciting news: my husband and I would be welcoming a new baby in December. While sharing this news with a new employer so soon after starting would typically be daunting for a parent-to-be, I felt nothing but excitement to be telling my colleagues. Since pMD values open communication,  I felt comfortable sharing the happy news and confident I would receive nothing but support. I am incredibly lucky to be part of a company that supports working parents.  However, not everyone is as fortunate in their work situations. Here are a few things to consider when researching whether a company provides flexibility and a supportive network around working parents.

Have you checked out Glassdoor?

There is so much you can find on the internet! Anonymous employee review sites, such as Glassdoor, can provide insight into a potential employer before you submit your application. When I was on the hunt for a new position, this was the first place I would go to either confirm my interest or remove a company from my list. When you’re on these sites, look for buzzwords that may indicate if an organization is family-friendly. Even if you’re not thinking of expanding your family anytime soon, these sites are a great place to get candid employee feedback about a company and its pros, cons, and thoughts on executive leadership.

Do those in leadership have children?

Nobody is going to be more understanding of a family, work-life balance than those who have been in your shoes. It’s typically helpful if those in leadership roles can empathize with your situation and understand if you need to take time off when your baby gets sick because they’ve experienced this first-hand themselves. How do you assess if those in leadership roles have children? This can be a bit trickier than simply reading online reviews. It’s okay if you need to do a little sleuthing before you get onsite! During an onsite interview, it can be helpful to take note of what you see around the office. Are there children’s drawings? Do you see family photos? When you ask what they did this past weekend, did any of it involve family-related activities? An onsite visit allows for an open line of communication with the company employees, so if you feel comfortable asking questions, definitely take advantage of your time there!

What benefits are offered?

Health benefits are important to research before starting with any company.  Having great health, vision, and dental benefits is extremely important when you’re thinking about taking care of your family. As a first-time mom, having good coverage affords me the option to take my child to the doctor on a regular basis, if needed. When you’re now thinking about more than just your own health, it’s critical that your employer provides strong and affordable health care options.

Are working conditions flexible?

Can you work from home if needed or are you required to be in the office from 8-5 every day? Having flexibility is so important for working parents. For example, if you’re a nursing mother, is your employer respectful of the time you need to pump? An employer that has no flexibility on hours spent in the office is something to consider for those who have a family, or are thinking of starting one in the future. Additionally, is the employer willing to work with you to optimize your working conditions? After welcoming my son last December, it was important for me to forgo all business travel until my son was at least a year old. I’m fortunate to work for a company that allows for such flexibility and accommodation.

 

Starting a family is one of the most exciting, and at times challenging, milestones in life. When you find an employer that is an advocate for working mothers and fathers, it can make a world of difference when trying to balance work and home life. While you can never know for certain what your situation may be in the future, taking steps to thoroughly do your research can help in making an educated decision as to what works best for both your career and your family.

Interested in working at pMD? Check out pMD's careers page for more information! To find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

Image: GJLP, CNRI, via Science Source

Here's The Latest in Health Care:


•  Seema Verma, administrator of the Centers for Medicare and Medicaid Services (CMS), announced that the agency will roll out a new "Meaningful Measures" initiative. This initiative will streamline quality measures and move away from fee-for-service models, allowing providers themselves to assess core issues surrounding high-quality care and the improvement of patient outcomes.  Read More

•  A new study recently found that stent procedures, most often used to relieve chest pain in patients who have blocked arteries, are virtually useless to many of them. The findings raise questions about how often stents should be used, if at all, to treat chest pain.  Read More

•  The future of personalized patient care is not in the hands of an EHR but that of apps. It's no secret that many EHRs lack usability and data integration functionality, which could eventually lead to their demise. EHRs aren't designed for treating patients. The problem is that EHR vendors have to engineer their products in a way that meets the government's criteria for meaningful use but at the expense of usable, exciting software. Early-adopter hospitals are already working on building their own apps to transform the future of personalized care.  Read More

•  On Wednesday, former President Barack Obama took to twitter to urge people to shop for Affordable Care Act health insurance. He encourages people to log on to the federal insurance exchange and sign up for coverage for next year.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

Happy Halloween, health care aficionados! On this day of candy, costumes, and frights, be on the lookout for some of these bizarre halloween-related incidents that may require ICD-10 codes. But I wouldn't get too comfortable with these codes just yet. Rumor has it that the latest revision to the International Classification of Diseases, or ICD as we fondly know it, is underway and the final ICD-11 will be released sometime in 2018. By this time next year, you could be looking at a new list of these unusual ICDs.

W49.01 - Hair causing external constriction, initial encounter
While wigs are a great addition to any Tina Turner, Cher, clown, or heavy metal ensemble, remember to double check the sizing before placing on head.

R44.1 - Visual hallucinations
It's not real, it's not real, it's not real.

X99.2 - Assault by sword or dagger
Your eight-year-old sure looks adorable in that knight costume but that plastic prop could do some real damage.

Z62.891 - Sibling rivalry
They can't both be Elsa from Frozen. It just won't end well.

W54.0 - Bitten by dog
You may love the idea of putting fido into a hot dog costume but he may have other ideas.

W22.02 -Walked into lamp post, initial encounter
Removing face masks while walking around at night might save you from bumping into those pesky lamp posts that may or may not have come out of nowhere.

Y93.D2 - Injury due to activity, sewing
Last-minute unicorn onesie costume alterations may result in injury.

R46.1 - Bizarre personal appearance
It's Halloween. Who doesn't this apply to?

Y93.D - Injury due to activities involving arts and crafts
Watch that hot glue gun when bedazzling your costume.

K03.81 - Cracked tooth
Trade in those Smarties and Jaw Breakers for Milky Ways and taffy.

Y93.75 - Injury due to activity, martial arts
Give sugar to your tiny ninja at your own risk.

Y04.1 - Human bite, initial encounter
It's all fun and games until someone takes their Twilight costume too literally.

A28.1 - Cat-scratch disease
See a black cat? Don't let it cross your path. Don't engage.

R10.84 - Generalized abdominal pain
...regretting that twentieth Reese's peanut butter cup...

If you'd like to find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

Image: Healthcare IT News via YouTube

Here's The Latest in Health Care:


•  On Wednesday, an advisory panel to the Centers of Disease Control and Prevention (CDC) recommended the use of Shingrix, a new shingles vaccine manufactured by GlaxoSmithKline. For the last decade, only one shingles vaccine has been available on the market. The head of the CDC still has yet to formally endorse the recommendation.  Read More

•  Genome sequencing is a technology that's becoming more mainstream and genomics expert J. Craig Venter is using that technology to help patients find out about any potentially fatal illnesses before symptoms come to light. However, many physicians are opposed to the exam as it may turn up false positives.  Read More

•  On Thursday, the President declared a public health emergency to deal with the opioid crisis. Agency and department heads are directed to use all appropriate emergency authorities to reduce the more than 140 deaths a day caused by the opioid epidemic.  Read More

•  Smaller practices are beginning to expand their offerings to include telemedicine services, in part to maintain patients that might otherwise go to outside telemedicine providers. Embracing telemedicine programs is also a way to attract patients from a broader region.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

What do you think of when you hear the word "cybersecurity"? If you’re anything like me, then this word can lead to a feeling of anxiety as headlines from the recent Equifax breach or the WannaCry attack flash across your mind. While cybersecurity can be an intimidating endeavor, take comfort in knowing that there are some straight forward steps that can be taken in order to strengthen cybersecurity in any industry. Before tackling preventative measures, however, we need to discuss what cybersecurity encompasses and its connection to health care.

What is cybersecurity?


Cybersecurity is "the body of technologies, processes, and practices designed to protect networks, computers, and data from attack, damage, and unauthorized access". This may seem like a lengthy definition, but it does cover all the aspects of cybersecurity and, more importantly, it highlights that cybersecurity is NOT just technology. Often, cybersecurity processes are more important than the technology itself in fending off malicious attackers.

Why is cybersecurity important in health care?


According to KPMG’s Cyber Healthcare & Life Sciences survey, 47% of health care providers reported instances of HIPAA violations or cyber attacks this year, rising 10% from the 2015 report. This number is only compounded by the increasing prevalence of connected devices, or the “Internet of Things,” which has contributed to the growth of new exploits that take advantage of lower security thresholds on these seemingly limited devices.

HIPAA’s Security Rule addresses some of the concerns that stem from having extremely valuable personal health information open to potential attacks by providing “a framework for managing risk.” The rule basically covers administrative safeguards, which includes performing risk analysis, designating security credentials, and training employees. This rule also details physical safeguards, which includes everything from locks on doors, to password protected workstations, to actual security guards. And finally, technical safeguards are also discussed, which is the part that you would more likely think of when you hear the word “cybersecurity” and includes things like access control and transmission security. While this framework gives broad suggestions on how to avoid potential security breaches, it doesn’t dive deep into specific suggestions, which begs the question:

What can we do to ensure our patients' health information is safe?


1. Stay up to date on industry trends and cybersecurity threats

One great resource to remain up to date is the HIMSS Cross-Sector Cyber Security reports. These reports are released frequently and include updates on attacks and vulnerabilities across health care and other industries.

2. Update systems regularly

A core lesson from the WannaCry attacks: updating software systems regularly and utilizing cloud-based systems (like pMD!) when possible to avoid running outdated versions of software can help ensure that known vulnerabilities are not left exposed.

3. Be wary of potentially harmful links

Spam email remains one of the top ways malware spreads throughout networks. Being vigilant of the links you click on and where you enter sensitive data is an easy way to avoid falling victim to phishing attacks.

4. Plan your response

If you do experience an attack, a response plan can help prevent exacerbating the situation through mismanagement. Coordinated response efforts are key to minimizing the impact of any attack and the plan should include addressing the root of the problem, not just the effects.

From employee training, to processes for handling sensitive patient data and reacting in the event of a violation, to technical specifications, one thing is clear: cybersecurity is a team effort.

If you have any questions about today’s blog post or would like to find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

More Resources:
http://nvlpubs.nist.gov/nistpubs/ir/2013/NIST.IR.7298r2.pdf
http://www.healthcareitnews.com/news/healthcare-organizations-are-underestimating-cybersecurity-risks

 

 

Image: Alden Chadwick/Getty Images

Here's The Latest in Health Care:


•  The Veterans Coordinated Access and Rewarding Experiences Act, or CARE act, would make it easier to share patient records between the VA and outside providers. The proposal hopes to continue to improve the veteran experience by building a high-performance network and address health IT problems.  Read More

•  On Wednesday, the F.D.A. approved the second gene-altering treatment that reboots a patient's own immune cells to kill cancer. The approval, however, is not without controversy. The side effects can be life-threatening and in some cases fatal. The treatment is currently available only at centers where doctors and nurses have been trained in providing this specific treatment.  Read More

•  At this year's Medical Group Management Association (MGMA) conference, two experts presented their advice on benchmarking. Benchmarking can help physician practices compare themselves to their competitors, evaluate their performance, and identify areas of strengths and weaknesses.  Read More

•  People with diabetes struggle with a lifelong challenge to maintain their blood sugar levels. However, new emerging diabetes technology may ease that blood testing process, some even avoiding the dreaded finger prick.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

pMD, a certified MIPS registry, makes understanding MIPS Improvement Activities scoring as easy as possible in Part 3 of the 4-Part series, MIPS Scoring, Simplified. In Part 1 of this series, we discussed the Basics of MIPS Scoring, and in Part 2, we discussed scoring for the Quality category. Today, we’ll discuss scoring for the Improvement Activities category. Then, in the series finale, Part 4, we’ll cover Advancing Care Information scoring, plus an overview of the MIPS payment adjustment calculation. So, without further ado, let’s talk Improvement Activities.

The Basics of Scoring the Improvement Activities Category



Improvement Activities scoring is, thankfully, much more straightforward than scoring for either Quality or Advancing Care Information. However, Improvement Activities is a completely new category, and unchartered territory can be confusing in and of itself. But, fear not, because when we boil Improvement Activities down to its essence, it’s a pass/fail category. So, as long as you are familiar with how the category applies to your particular situation, you should pass with flying colors.

Special Group Attributes: Small Group, Rural Practice, HPSA, Non-Patient Facing



The maximum number of points available under Improvement Activities is 40. To earn the full 40 points, the first thing you’ll need to determine is how many improvement activities you or your group needs to submit to earn the full points. The number of activities you need to submit is determined by whether or not your group qualifies for special scoring. Four attributes result in special scoring for Improvement Activities:

1) small practice;
2) practicing in a health professional shortage area (HPSA);
3) practicing in a rural area; or
4) qualify as non-patient facing clinicians.

If any of these four attributes apply to you or your group, then your Improvement Activities category will be scored differently than groups that do not have one of these attributes. For special attribute groups only, each medium-weighted improvement activity is worth 20 points, and each high-weighted improvement activity is worth 40 points. That means, to earn the full 40 points, special attribute groups only have to submit:

* 1 high-weighted improvement activity
or
* 2 medium-weighted improvement activities

To confirm whether one of these attributes applies to your group, head to the QPP website. Enter your NPI at this page, and a chart like this will appear:

You can see in the chart that this provider is considered a small group, but does not practice in a HPSA nor in a rural area, nor are they a non-patient facing provider. Note that all four of these attributes are the same for both the individual clinician (as listed under “For this clinician at this practice”) and the group practice (as listed under “For this practice”). This should always be the case - if they’re not, it’s worth a call to figure out why, since it’s possible CMS’s records are amiss. But, if any of these four attributes - small practice, rural, non-patient facing, or HPSA - says “yes”, then you can submit less improvement activities than larger practices, as discussed above.

Standard Groups



If none of these four special attributes apply to you, your chart on the NPI look up page will look similar to this:

Note that the four attributes relevant to Improvement Activities - non-patient facing, small practice, rural, and HPSA - all say “No.” This means you and your group qualify for standard Improvement Activities scoring, so each medium-weighted Improvement Activity is worth 10 points, and each high-weighted Improvement Activity is worth 20 points. Based on that, if you want to earn the full 40 points for this category, you have to submit:

* 2 high-weighted improvement activities
or
* 4 medium-weighted improvement activities
or
* 1 high-weighted improvement activity AND 2 medium-weighted improvement activities

Reporting Improvement Activities



At the end of the performance period, you’ll attest to successful performance of your chosen improvement activities, for at least 90 days. So, using your submission mechanism, you’ll attest by indicating “Yes, I completed this improvement activity” or “No, I did not complete this improvement activity.” If you chose the correct number of improvement activities, and you positively attest to completing each activity, you’ll receive the full credit for the Improvement Activities category.

There are just a few more things to keep in mind about this category. First, you can’t earn bonus points for the Improvement Activities category. So, even if you submit more than your required activities, you’ll only receive 40 points. Second, everything outlined above applies to clinicians that are not participating in APMs. If you participate in some form of APM, then the rules for Improvement Activities are different for you. Third, many groups fret about what completing one of these activities actually means. Unfortunately, CMS is not giving a lot of guidance on this, and they don’t intend to give more. As far as I can find, there are only two decent sources of information to explain what each improvement activity requires. The QPP website’s improvement activities page, found here, and the “MIPS Data Validation Criteria” zip, which is available in the QPP Resource Library, found here. One helpful rule of thumb is to think about what documentation you or your group would point to if CMS ever audited your Improvement Activity attestation. If you feel confident that you have enough documentation to fully prove that you completed the specified activity, then you are in good shape.

Ok! See? I told you Improvement Activities scoring is easier! Now, stay tuned for Part 4, where we’ll discuss how the Advancing Care Information section is scored and how the final payment adjustment is determined. And as always, if you have any questions or would like to find out more about our MIPS registry, give us a call! To find out more about pMD's suite of products, which includes charge capture, secure messaging, and care coordination software and services, please contact pMD.

References:

Improvement Activities is a completely new category: “Improvement Activities: In this new performance category for 2017, clinicians are rewarded for care focused on care coordination, beneficiary engagement, and patient safety.” See https://qpp.cms.gov/mips/improvement-activities.

The maximum number of points available under Improvement Activities is 40: “To get the maximum score of 40 points for the Improvement Activity score…” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also “To achieve the maximum score of 40 points for the Improvement Activity score…” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3758. (“[W]e are only requiring a total of 40 points to receive the highest score for the improvement activities performance category.”)

Four attributions indicate your group qualifies for special scoring, (1) if you are a small practice; (2) if you practice in a health professional shortage area (HPSA); (3) practice in a rural area; or (4) non patient facing clinicians: “For these clinicians [small groups, non-patient facing, rural area, or HPSA], each medium-weighted activity is worth 20 points of the total Improvement Activity performance category score, and a high-weighted activity is worth 40 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

For special attribute groups only, each medium weighted improvement activity is worth 20 points, and each high weighted improvement activity is worth 40 points: “For these clinicians [small groups, non-patient facing, rural area, or HPSA], each medium-weighted activity is worth 20 points of the total Improvement Activity performance category score, and a high-weighted activity is worth 40 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

Standard Improvement Activities scoring means each medium weighted improvement activity is worth 10 points, and each high weighted improvement activity is worth 20 points: “Each medium-weighted activity is worth 10 points of the total Improvement Activity performance category score, and each high-weighted activity is worth 20 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

For standard scoring, if you want to earn the full 40 points for this category, you have to submit 2 high weighted improvement activities, or 4 medium weighted improvement activities, or 1 high weighted improvement activity AND 2 medium weighted improvement activities: “Groups with more than 15 clinicians: Each activity is weighted either medium or high. To get the maximum score of 40 points for the Improvement Activity score, you may select any of these combinations: 2 high-weighted activities; 1 high-weighted activity and 2 medium-weighted activities; Up to 4 medium-weighted activities.” See MIPS Improvement Activities Fact Sheet pdf, pg. 2-3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

To receive full credit, you must report successful performance of your chosen improvement activities for 90 days: “You must attest by indicating ‘Yes’ to each activity that meets the 90-day requirement (activities that you performed for at least 90 consecutive days during the current performance period).” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also 81 FR 77186, https://www.federalregister.gov/d/2016-25240/p-2387, (“we are finalizing at § 414.1360 that MIPS eligible clinicians or groups must perform improvement activities for at least 90 consecutive days during the performance period for improvement activities performance category credit.”)

So, using your submission mechanism, you’ll attest to completing your chosen improvement activities: “Eligible clinicians may submit their improvement activities by attestation via the CMS Quality Payment Program website, a qualified clinical data registry, a qualified registry, or, when possible, from their electronic health record system. Groups of 25 or more may choose to use the CMS Web Interface.” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

You will receive the full points available for each improvement activity that you positively attest to completing: “In alignment with the reduction in total points required, we are finalizing that the following scoring that will apply to MIPS eligible clinicians who are a non-patient facing clinician, a small practice, a practice located in a rural area, or practice in a geographic HPSA or any combination thereof: *Reporting of one medium-weighted activity would result in 20 points or one-half of the highest score. *Reporting of two medium-weighted activities would result in 40 points or the highest score. *Reporting of one high-weighted activity would result in 40 points or the highest score. In alignment with the reduction in total points required, we are finalizing the following scoring that will apply to MIPS eligible clinicians who are not a non-patient facing clinician, a small practice, a practice located in a rural area, or a practice in a geographic HPSA: *Reporting of one medium-weighted activity would result in 10 points which is one-fourth of the highest score. *Reporting of two medium-weighted activities would result in 20 points which is one-half of the highest score. *Reporting of three medium-weighted activities would result in 30 points which is three-fourths of the highest score. *Reporting of four medium-weighted activities would result in 40 points which is the highest score. *Reporting of one high-weighted activity would result in 20 points which is one-half of the highest score. *Reporting of two high-weighted activities would result in 40 points which is the highest score. *Reporting of a combination of medium-weighted and high-weighted activities where the total number of points achieved are calculated based on the number of activities selected and the weighting assigned to that activity (number of medium-weighted activities selected × 10 points + number of high-weighted activities selected × 20 points). See 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3758.

No bonus points are awarded in the Improvement Activities category: “The most any MIPS eligible clinician or group can achieve for the improvement activities performance category is 40 points, so if more activities are selected than, for example, 4 medium-weighted activities, the total points that could be achieved is still 40 points.” See 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3770.

Participants in APMs have different Improvement Activity scoring than is outlined above: See MIPS Improvement Activities Fact Sheet pdf, pg. 3-4, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

Unfortunately, CMS is not giving a lot of guidance on this, and they don’t intend to give more: “We are not planning to issue any more specific language around the activities for the transition. We kept it simple, and for the reason that we're just doing a simple adaptation. We aren't requiring any specific data to be submitted. So, for the transition year, what you find on the QPP website for the improvement-activities description is all that we're issuing at this point for the transition year.” See Webinar Transcript, held on 12/13/16, “Merit-Based Incentive Payment System (MIPS) Overview: Understanding Advancing Care Information (ACI) & Improvement Activities,” available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-transcript.pdf

Participants should consider the documentation they have that support the chosen improvement activities, in case of audit: “So, for improvement activities, we're not exactly requiring documentation, but what we are telling providers is that you should retain copies of medical records, charts, reports, and any electronic data utilized, to determine which measures and activities were applicable and appropriate for their scope of practice, and patient population for reporting under MIPS for up to 10 years after the conclusion of the performance period, to prepare For verification in the event that you're selected for an audit. This record-retention timeframe aligns with the record-retention timeframes already in place for the APMs, either established in regulation or included in participation agreements. CMS may request any records or data retained for the purposes of MIPS for up to six years and three months. And we will provide audit specifications through subreg. guidance. And MIPS-eligible clinicians or groups selected for data validation audits will be provided instructions and examples of documents required.” See Webinar Transcript, held on 12/13/16, “Merit-Based Incentive Payment System (MIPS) Overview: Understanding Advancing Care Information (ACI) & Improvement Activities,” available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-transcript.pdf

Image: Ben Edwards/The Image Bank, via Getty Images

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