Medicare Compliance & Reimbursement

Keep this helpful outline nearby when you start to report your CPIA measures.

The Merit-Based Incentive Payment System (MIPS) is the entryway to adopt MACRA and is underway as one of the options in the new Quality Payment Plan (QPP) for Medicare. If you’re in the loop you know that the Clinical Practice Improvement Activities (CPIA) is an entirely new scoring section required by MACRA and impacts 15 percent of your MIPS score. But, if this sounds like a gibberish, read on to understand what CPIA is and what it means to you. 

Refresher course. MIPS has four categories — Cost, Quality, CPIA, and Advancing Care Information (ACI) — and four paces for entry and data reporting under the new payment system. —no participation, minimal participation, partial-year, and full-year. At the very least, you’re asked to report one measure under either CPIA, Quality, or ACI to avoid a 4 percent negative impact. Keep in mind, with each passing year that the penalty rises with an estimate of a 9 percent penalty to your payments by 2022.

2022 scenario: If your practice earns $1 million in revenue with a fairly standard 60 percent overhead and bills Medicare for a third of your patients, right now, that’s $600,000 in expenses and a net of $400,000.

Because that 9 percent penalty or bonus is calculated based on your revenue, that’s a roughly $30,000 bonus or penalty to your net income, making it range from $370,000 to $430,000. For your practice, the difference and cost of failing to adopt MIPS versus maxing out the bonus is roughly $60,000: 0.09 x ($1,000,000 x 1/3) = $29,700.

Overview. CPIA offers more than 90 activities to report under nine subcategories. With options for small and rural practices and a minimal amount of data required to avoid a penalty, CPIA is the easiest MIPS measure to embrace.

Take a look at the nine CPIA subcategories:

• Expanded practice access. Example: the offer of telehealth services to your patients. 
• Population management. Example: Take part in improving the health status in your community.
• Care coordination. Example: The timely communication of abnormal test results with a follow-up.
• Beneficiary Engagement. Example: Institute group visits for common chronic conditions.
• Patient safety and practice assessment. Example: Engage in an AHRQ-listed patient safety organization.
• Participation in an APM. Example: Participate in a Shared Savings Program Track 1 program.
• Achieving health equity. Example: Take part in State-Funded Innovation Models.
• Integrating behavioral and mental health. Example: Implement depression screening and follow-up plan.
• Emergency preparedness and response. Example: Participate in domestic or international humanitarian volunteer work for a minimum of six months.

Points review. Each activity under the subcategories is weighted either “medium” or “high” with 10 points awarded to medium-level activities and 20 points for the higher group. The total amount of points needed to reach your 15 percent threshold under CPIA is 40.

However, if your practice has less than 15 practitioners or is considered a rural or underserved practice, your measure requirements are lessened. Small practices’ data will be weighted at a higher weight with medium equalling 20 points and high at 40. Under these CPIA restrictions, larger group practices would likely report two to four measures while smaller offices would participate in one to two activities.

Take a look at the MIPS factsheet on Clinical Practice Improvement Activities here: https://qpp.cms.gov/measures/ia.