Improvement Activity Attestation: The Waiting Game

We are now into the fourth quarter of the first year of the Quality Payment Program and CMS has yet to finalize and publish a mechanism to accept attestations for the MIPS Improvement Activity (IA) performance category for radiologists using the claims-based submission option for reporting. Groups reporting via qualified registry or qualified clinical data registry (QCDR) will be able to report the IA category through that mechanism.

The deadline for reporting related to the 2017 performance year is March 31, 2018, not December 31, 2017.  Accordingly, there is still time for CMS to publish a mechanism to accept IA attestations for the claims-based submission option.

Also, keep in mind that for those participating in MIPS as a group, only one attestation for the TIN will be needed.  For those participating in MIPS as individuals, an attestation for the IA category will need to be submitted for each MIPS eligible clinician (NPI/TIN).

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.

Lauren Sloan, MHA, RD, LD
Director of Regulatory Affairs