1. 2019 Improvement Activities
A Guide for CRNAs
This brief video was prepared by the AANA’s Research and Quality department as an overview of the Improvement Activity Performance category changes for the 2019 calendar year. These changes were published in the CMS Physician Fee Schedule Final Rule, in November 2018.

2. MIPS Reporting Categories
Quality
Improvement Activities (IA)
Promoting Interoperability (PI)
Cost
*Most CRNAs will report data for the Quality and IA categories.
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MIPS Eligible Clinicians (EC) can report data for these categories.
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3. Improvement Activity Performance Category
Measures participation in activities that improve clinical practice
Apply to individual clinicians and group practices
CMS provides a list of 118 improvement activities to choose from in CRNAs should report IAs that are applicable to their practice.
Individual practitioners and groups document and attest to participation in activities that improve clinical practices. For 2019, CMS compiled a list of 118 IAs for providers to choose from.
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4. 2019 MIPS IA Weight 15% of final score
(Applicable to all MIPS-eligible clinicians)
(For CRNAs NOT reporting Promoting Interoperability [PI], but with applicable Cost Measures)
(For CRNAs NOT reporting PI* with NO applicable Cost Measures)
*PI – Promoting Interoperability
This illustrates the weights of each performance category in relation to the MIPS Final Score, which is calculated as percentage. The categories can be re-weighted based on applicability of the Promoting Interoperability and Cost Measures. The first chart shows the weight of the Improvement Activity category at 15%, when a provider reports all four MIPS categories; it remains at 15% when reporting no PI or no PI or Cost.
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5. Improvement Activities Participation Requirements - OVERVIEW
CRNAs must report a minimum 90 consecutive days during the performance year
Providers can select applicable Improvement Activities approved for the MIPS program in 2019
Participation in a Qualified Clinical Data Registry (QCDR) satisfies several IAs
Documentation of IAs is very important. Providers should maintain documents such as an improvement plan, meeting minutes or action items.
The performance period for IAs in 2019 is a minimum of 90 consecutive days. CMS does not provide rules for interpreting or documenting Improvement Activities. CRNAs report measure data that reflect healthcare care processes, outcomes and patient experiences. Providers can select from 118 IAs approved for MIPS in Participation in a QCDR satisfies several IAs.
Documentation of IAs is very important, although CMS does not offer specific guidelines or documentation requirements.
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6. Improvement Activities Participation and Special Status - OVERVIEW
Most CRNAs will need to report at least two IAs (Improvement Activities) based on status, to earn full credit (no special status)
Individual clinicians and groups who qualify for special status have reduced MIPS reporting requirements. They receive double points for each medium and high-weighted activity submitted with one of the following special statuses:
Small practice (15 or fewer clinicians billing under a practice TIN)
Non-patient facing (100 or fewer Medicare Part B patient-facing encounters)
Rural
Health Professional Shortage Area (HPSA)
Most CRNAs will need to report at least two IAs to earn full participation credit. There are special statuses for which CRNAs can receive double points for medium and high-weighted IAs: Small practice, Non-patient facing, rural, HPSA
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7. MIPS 2019 Full Participation Requirements
Performance category
IMPROVEMENT ACTIVITIES-- 15%
What you need to do
For patient-facing CRNAs: try to complete and report 2-4 activities that add up to a total of 40 points
For CRNAs who are non-patient- facing, in groups with fewer than 15 participants, or in a rural or health professional shortage area: try to complete and report 1-2 activities that add up to a total of 40 points
Category weight = 15%
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8. Improvement Activities Participation and Special Status
Patient-facing individuals or groups (no special status) report up to 4 IAs that add up to a total of 40 points:
Option 1: Report 2 high-weighted activities (2 x 20 pts)
Option 2: Report 1 high-weighted (20 pts) and 2 medium-weighted activities (2 x 10 pts)
Option 3: 4 medium-weighted activities (4 x 10 pts)
Non patient-facing individuals, groups with less than 15 members, rural or HSPAs
Report up to 2 IAs: 1 high-weighted IA or 2 medium weighted
Special status clinicians receive double points, so high-weighted activities are worth 40 points; medium-weighted are 20 points
Looking at the requirements more closely, patient-facing encounters are defined as those billed by individuals or groups for general office visits, outpatient visits and procedure codes. However, they do not include traditional anesthesia billing codes.
A non patient-facing CRNA in solo practice is one that bills for 100 or few patient-facing encounters during the performance period. A non patient-facing group contains more than 75% of clinicians billing under the TIN that meet the criteria for a non-patient individual clinician.
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9. New Approved 2019 Improvement Activities
IA’s – New for 2019
Weighting
Relationship-Centered Communication
Medium
Financial Navigation Program
Patient Medication Risk Education
High
Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support
Comprehensive Eye Exams
Completion of Collaborative Care Management Training Program
CMS added these 6 new Improvement Activities for 2019, with associated weights.
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10. Suggested 2019 Improvement Activities for Consideration
ACTIVITY ID
ACTIVITY NAME
ACTIVITY WEIGHTING
IA_PM_21
Advance Care Planning
Medium
IA_PSPA_22
CDC Training on CDC's Guideline for Prescribing Opioids for Chronic Pain
High
IA_PSPA_23
Completion of CDC Training on Antibiotic Stewardship
IA_BE_22
Improved Practices that Engage Patients Pre-Visit
IA_PSPA_3
Participate in IHI Training/Forum Event; National Academy of Medicine, AHRQ Team STEPPS® or Other Similar Activity
IA_PSPA_1
Participation in an AHRQ-listed patient safety organization.
IA_AHE_6
Provide Education Opportunities for New Clinicians
IA_PSPA_32
Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support
IA_PSPA_8
Use of Patient Safety Tools
IA_PSPA_7
Use of QCDR data for ongoing practice assessment and improvements
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(IA_BE_1) Use of certified E.H.R to capture patient reported outcomes
(IA_BE_15) Engagement of patients, family and caregivers in developing a plan of care
(IA_BMH_3) Unhealthy alcohol use
(IA_CC_2) Implementation of improvements that contribute to more timely communication test results
(IA_EPA_3) Collection and use of patient experience and satisfaction data on access
(IA_PM_15) Implementation of episodic care management practice improvements

11. Reporting Improvement Activities
Individual and group practices can attest or report using:
Qualified Clinical Data Registries (QCDRs)
Qualified Registries
Log in to QPP website and attest
Log in to QPP website and upload IA data files
Third-party intermediaries such as health IT and CMS-approved survey vendors
CRNAs in solo or group practices have these options for reporting MIPS data to CMS: Qualified Clinical Data Registries (QCDRs), Qualified Registries, direct submission of MIPS data from a certified EHR or Health IT system; MIPS CQMs. Group practices have additional options, including CMS Web Interface for larger groups and measure data from Medicare Part B claims. Some APMS also qualify for special MIPS scoring.
It is important to note that individual CRNAs can submit the same quality measures using more than one reporting type. The measure with the highest number of achievement points will be selected for performance category scoring.
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12. Importance of IA Documentation and Audit
CMS does not provide much detail about how to interpret Improvement Activities, or the type of documentation required.
However, CMS may request documentation during an audit. Therefore, providers should maintain documents such as an improvement plan or meeting minutes.
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13. Additional Resources QPP website: https://qpp.cms.gov
QPP Participation Status Tool:
QPP Resource Library:
Phone: (Monday through Friday)
Determination periods for the 2019 reporting year:
First: October 1, September 30, 2018
Second: October 1, September 30, 2019
Additional information about reporting requirements, scoring and data submission requirements 2019 can be found here. CMS offers resources in print, video and webinars. Use your National Provider Identification (NPI) number to use the Participation Status tool, which contains data from two determination periods that indicate eligibility for reporting MIPS.
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