The Merit-based Incentive Payment System (MIPS) includes four performance categories. Although Quality, Promoting Interoperability, and Cost often receive the most attention, the Improvement Activities (IA) category is equally important. In some cases, IAs may even have a greater impact on patient outcomes and facility operations because of their direct focus on care delivery, patient engagement, and operational efficiency.

The broadly applicable Provide 24/7 Access to Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record (IA_EPA_1) measure was retired in 2025, to the disappointment of many healthcare professionals. However, updates to the IA category have introduced more flexibility and a broader range of options for healthcare organizations in 2025. The most notable change is the removal of the “medium” and “high” weighting system for IA measures. As a result the often-cumbersome process of selecting IA measures based on their point values is no longer an issue. Small practices (15 or fewer unique NPIs) must now select any only one of the 104 IA measures, while larger practices (16 or more NPIs) must only select any two.

The following are examples of measures that have broad applicability across a range of specialties.

Promoting Clinician Wellbeing (IA_BMH_12)

The Association of American Medical Colleges (AAMC) has projected troubling statistics on the future shortage of medical doctors. By 2034, there is a projected shortage of between 17,800–48,000 primary care physicians and between 21,000–77,100 non-primary care physicians. According to the American Academy of Ophthalmology, the shortage of ophthalmologists necessary to meet demand will reach critical levels by 2035.Administrators are tasked with finding ways to improve work environments for their doctors to prevent these valuable care providers from leaving the healthcare industry, despite the increasing volume of patients requiring care.

The IA_BMH_12 measure attempts to address this opportunity for feedback and improvement by directing administrators to “Develop and implement programs to support clinician well-being and resilience.”

The measure criteria provide examples of how to survey providers on ways to improve their work experience and identify key sources of job dissatisfaction. Administrators then use the survey data to develop a training program for providers and staff to address the key issues they discover.

For example:

  • If a survey shows that providers are not getting adequate time for a meal break each shift, administration could consider adjustments to the staff and patient schedules.
  • If providers are struggling to locate information in patient charts, the administration could provide additional EHR training or possibly discover efficiencies within the software to streamline charting processes or implement the use of scribes.

This IA measure requires the completion of a written implementation plan based on survey results, providing an opportunity for providers and staff to collaborate in a supportive environment where they can be transparent, feel heard, and contribute to meaningful, positive changes in their organization.

Practice-Wide Quality Improvement in MIPS Value Pathways (IA_MVP)

Are you planning on participating in an MVP for your specialty? By creating a plan that includes the measures you will report for the MVP, you can also meet this IA measure.

To meet this measure, administrators will document how the entire staff, clinical and non-clinical, will participate in a purposeful, goal-driven improvement strategy for at least three quality measures in the MVP. This planning helps healthcare organizations meet the IA measure and improve their quality scores in the process.

Participation in Private Payer Clinical Practice Improvement Activity (CPIA) (IA_PSPA_12)

While practices are working hard to provide great care, raise their MIPS scores, and keep providers’ ratings high, the insurance payers are, too. Payers participating in Medicare contracts must meet certain criteria to achieve their “star ratings” as preferred plans for both patients and for Medicare. The objective of this measure is to improve the quality of care and health outcomes for patients by participating in private payer activities for improvement. With this measure, practices participate with a payer for the benefit of their shared patients.

To meet the measure an health organization must show confirmation of participation in a private payer clinical practice activity.

One example our ophthalmology consultants have seen is a practice partnering with a payer early in the third quarter to identify diabetic patients who have not received their annual diabetic eye exam yet that year. The practice commits to contacting those mutual patients in an attempt to bring them in for an appointment before the end of the year. This method is a triple win: The documentation serves the payer and health organization in meeting their measures, and the patient receives appropriate diabetic care.

Enhance Engagement of Medicaid & Other Underserved Populations (IA_AHE_1)

Statistically, patients who are most at-risk are those on Medicaid. These risks often make it more challenging to treat these patients due to complex comorbidities and other social barriers, such as transportation. This IA measure addresses care barriers that affect medically and socially underserved populations, targeting the disparities and inequities that outdated organizational policies can create (e.g., a policy that limits the number of Medicaid-primary patients scheduled per day).

Developing and implementing a written triage policy that ensures patients are not treated differently based on their insurance status is one way to meet this IA measure. While your organization may not have specific, written policy limitations on the number of patients who may be scheduled per insurance carrier, there may be unwritten or implied limitations. By creating and abiding by a written and clearly stated protocol in which patients are scheduled based on need, not insurance, you can support this IA measure.

Additionally, organizations are encouraged to use helpful resources such as the Protocol for Responding to and Assessing Patients’ Assets, Risks, and Experiences (PRAPARE) screening tool to gain a better understanding of their patient population’s needs before developing an equity policy in their organizations. Those tools can be helpful when developing written protocols to help reduce barriers to care and support this IA measure (e.g. informing patients of transportation services such as  Medicaid non-emergency medical transportation). The protocol can be as simple as offering a handout providing the phone number for your state or county’s Medicaid transportation service.

In case of an audit of this IA measure, consider storing documentation reports from your PM system showing time-to-treat data relative to insurance coverage, keeping copies of your written policies, recording trainings and discussions regarding the implementation of these policies, and keeping screenshots of patient examples where the policies were implemented.

Summary

IAs offer more than just a portion of your MIPS score; they present a meaningful opportunity to shape the culture and effectiveness of your practice. Thoughtfully and collaboratively selecting and implementing IA measures with simplified requirements that align with your healthcare organization’s goals can create positive changes that extend beyond compliance and directly enhance provider satisfaction, care quality, health equity, and patient outcomes.