In its final rule, the Centers for Medicare & Medicaid Services (CMS) added accredited CME as an improvement activity in the changes for the Quality Payment Program (QPP). The changes take effect on January 1, 2018, the second year of the QPP, as part of the Medicare Access and Chip Reauthorization Act of 2015 (MACRA).
This rule now gives accredited providers in the ACCME System the opportunity to help clinicians meet CMS expectations, which can prevent financial penalties and offer financial incentives to clinicians who engage in quality and performance improvement activities. The elements of the new rule provide flexibility and freedom for educators to engage with clinicians in improvement activities that are meaningful for those learners. The rule outlines a process that can be used across specialties and practice types, can apply to a broad range of content areas, and utilize a range of outcome measures. The inclusion of accredited CME reflects recommendations from the ACCME and others that CMS develop a process that allows accredited providers flexibility and permission to meet clinician needs. Read the ACCME’s letter to CMS here.
To meet the criteria for improvement activities in the Merit-Based Incentive Payment System (MIPS) of QPP, accredited CME providers need to implement activities that:
- address a quality or safety gap that is supported by a needs assessment or problem analysis, or support the completion of such a needs assessment as part of the activity;
- have specific, measurable aim(s) for improvement;
- include interventions intended to result in improvement;
- include data collection and analysis of performance data to assess the impact of the interventions; and
- define meaningful clinician participation in their activity, describe the mechanism for identifying clinicians who meet the requirements, and provide participant completion information.
You can find the criteria described above in the PDF of the final rule on page 624.
Opportunities for Accredited CME Providers
The inclusion of accredited CME in MIPS offers an opportunity for providers to demonstrate the value of CME in promoting clinician engagement in efforts to improve performance, quality, and safety. Accredited CME providers can support their clinician learners in several ways: you can help clinicians understand how to identify improvement activities, facilitate those activities, and then assist clinicians in attesting to their participation; and you can plan and present CME activities that will count as improvement activities.
We’ve provided a list of resources below that can enhance your understanding of MIPS and that you can share with your clinician learners to support their participation.
CME that Counts for MIPS
You’ll see that the MIPS improvement activity criteria are well-aligned with the ACCME Accreditation Criteria and may align with your CME mission and program. You may already be delivering activities that will fulfill the criteria. Delivering CME that counts for MIPS within the already existing framework of a clinician’s educational home could streamline and demystify the process for clinician participation.
CME + MOC + MIPS: You’ll see that the MIPS criteria are also aligned with the American Board of Internal Medicine (ABIM) Practice Assessment Maintenance of Certification (MOC) requirements. This offers another opportunity for CME providers to ease the burden on clinicians by delivering activities that meet multiple expectations. Providers can offer activities that enable clinicians to earn CME credits and ABIM Practice Assessment MOC points—and those same activities can count for MIPS. More information about CME that Counts for ABIM MOC is available here.
We suggest that accredited providers:
- Review the MIPS improvement activity criteria described in the bulleted list above.
- Review the letter ACCME sent to CMS about how accredited CME can support MIPS goals. The letter includes a few examples of accredited CME activities that focus on quality and performance improvement and appear to meet MIPS expectations.
- Identify activities that you are designing to change performance or patient outcomes. (ACCME Accreditation Criterion 3)
- Identify activities that will be part of a quality improvement initiative for individual clinicians or for small or large groups.
- Identify activities that will be offered for ABIM Practice Assessment MOC points.
- Consider teaching clinicians how to implement quality measures into their practice and supporting them in implementing these performance improvement programs.
Providing Guidance for Clinicians
- 2017 Improvement Activities: Data submission for 2017 begins January 2, 2018 and ends on March 31, 2018. More information is available here. Note: the new process outlined above does not apply to 2017 Improvement Activities.
- 2018 Improvement Activities: Clinicians can report their participation in accredited CME activities that meet the MIPS criteria beginning in 2018. You can help clinicians identify CME activities and other activities that meet MIPS criteria and educate them about how to attest to their participation and report their activities. More information about MIPS is available in the resources listed below.
Next Steps for Accredited CME
The ACCME is working with CMS to obtain specific guidance about how clinicians should attest once they have completed the activity. In addition, we anticipate collaborating with the CME community and CMS to identify a simple, nimble mechanism for reporting clinician engagement that will relieve the burden on clinicians.
As more information becomes available we will share it with the CME community and we will continue to provide guidance about how accredited CME providers can implement activities that count for MIPS improvement activities.
If you have questions, please contact us at firstname.lastname@example.org.
The following resources are available on the CMS website:
- MIPS Improvement Activities Fact Sheet: Overview that includes guidance for submitting improvement activities
- Quality Payment Program Fact Sheet: Overview of Quality Payment Program Year 2 Final Rule
- Quality Payment Program Resource Library: Resources including specific information about MIPS measures by clinician profession
- Merit-based Incentive Payment System: 3 Ways to Participate in 2017: Infographic that summarizes three ways to participate in 2017 and includes links to additional resources
- Quality Payment Program website: Overview of eligibility and participation guidelines, with links to additional resources
The American Academy of Family Physicians (AAFP) published a list of acronyms and definitions on its website: MACRAnyms: Acronyms and Terms Related to MACRA.