Improvement Activities (IA) for different periods

[Aditya Deshpande - Head Product - FIGmd]

Hi Ivana,

The CMS Final rule allows the Eligible Clinician to submit each IA for same or different period.

Within each performance category, we are finalizing specific requirements for full participation in MIPS which involves submitting data on quality measures, improvement activities, and use of certified EHR technology on a minimum of any continuous 90 days up to the full calendar year in 2017 in order to be eligible for a positive MIPS payment adjustment. It is at the MIPS eligible clinician’s discretion whether to submit data for the same 90-day period for the various measures and activities or for different time periods for different measures and activities. Note that during the 2017 transition year, MIPS eligible clinicians may choose to report a minimum of a single measure in the quality performance category, a single activity in the improvement activities performance category or the required measures in the advancing care information performance category, in order to avoid a negative payment adjustment.

However, in the API, the options for performanceStart and performanceEnd exists outside the measurement. If we try to submit it 2 times, each time a different measure for example IA_BE_22 in one case and IA_BE_13 in another, we get 

{

    "error": {

        "type": "DuplicateEntryError",

        "message": "Duplicate entry for key submission_id_category_submission_method_submitter_id_and_type",

        "details": {

            "submissionId": <hidden by Aditya>

        }

    }

}

In such a scenario, how do I submit different IA attestations for different periods.

Regards

Adi

Aditya Deshpande

Head - Product

FIGmd Inc.

[Ivana Ng]

Hi Aditya - 

Please refer to https://groups.google.com/d/msg/qpp-apis/rCoFgIF3rag/0k-Ld4WlAwAJ.

The intent of that excerpt in the QPP Final Rule is to say that submitters may use different time periods for each category (i.e. measurement-set), not each measure (i.e. measurement). So the API is interpreting the policy correctly. 

We've passed along feedback to the CMS Policy team to modify the language to make this clearer.

-Ivana