Improvement Activities: requirements, evidence, and documentation.

This volume is the full 2026 inventory as it applies to anesthesia: what each activity asks, what Graphium clients can typically use as evidence, and the documentation CMS expects if you are audited. For how the category is scored and how many activities you actually need, see the companion volume, QPP Program Mechanics, which also carries a one-page summary of everything below.

How This Category Works in 2026

Activity weighting was eliminated in 2025. There is no longer a high-weight or medium-weight distinction. You attest to a fixed number of activities and receive full credit:

• MVP reporting: 1 activity, regardless of special status.
• Traditional MIPS with small practice, rural, HPSA, or non-patient-facing status: 1 activity.
• Traditional MIPS, all others: 2 activities.

Each activity must be performed for at least 90 consecutive days within the calendar year, unless the activity description specifies otherwise. Group attestation requires that at least 50% of the clinicians in the TIN performed the activity for a continuous 90-day period within the same performance year, unless the activity specifies otherwise. The clinicians do not have to perform the activity concurrently.

Attesting to more activities than required does not increase your score.

Category weight is separate from the number of activities required. CMS defines a small practice as 15 or fewer clinicians billing under a TIN. For small practices reporting traditional MIPS or an MVP, the standard weights with Promoting Interoperability reweighted to zero are Quality 40%, Cost 30%, and Improvement Activities 30%. If Cost is also reweighted to zero, the weights are Quality 50% and Improvement Activities 50%. Confirm your CMS small-practice designation and applicable weights in the QPP Participation Status Tool. Source: CMS 2026 Small Practices Guide.

Documentation must be retained for six years after submission. For each activity, keep: start and end dates, the goal or metric, a description of the process being improved, the staff involved, the technology used (with screenshots where possible), workflow documentation, and evidence of the outcome. Full validation requirements are at https://qpp.cms.gov/mips/improvement-activities.

Activities Removed or Renumbered Since Our Last Manual

Our previous manual listed several activities that no longer exist. Do not attest to these:

Retired Activity	Status
IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians	Removed effective 2025.
IA_AHE_8: Create and Implement an Anti-Racism Plan	Eliminated with the retirement of the Achieving Health Equity subcategory.
IA_ERP_4: Implementation of a PPE Plan	Removed effective 2025.
IA_CC_1: Specialist Reports Back to Referring Clinician	Removed for 2026.
IA_CC_2: Improvements Contributing to More Timely Communication of Test Results	Removed for 2026.
IA_PSPA_8: Use of Patient Safety Tools	No published entry for 2025 or 2026. Treat as removed. Groups that relied on it should move to IA_PSPA_16 (decision support and standardized treatment protocols), which covers ERAS protocols and surgical risk calculators, or to IA_PSPA_34 below.
IA_AHE_1 / IA_AHE_6	The Achieving Health Equity subcategory was retired for 2026. "Enhance Engagement of Medicaid and Other Underserved Populations" now lives at IA_EPA_7. "Provide Education Opportunities for New Clinicians" now lives at IA_EPA_8.

CMS also introduced a new subcategory for 2026, Advancing Health and Wellness, which currently contains a single activity (IA_AHW_1, Chronic Care and Preventative Care Management for Empaneled Patients). It is not a natural fit for anesthesia.