The 2017 QRDA III Implementation Guide does not fully address how to submit MIPS IA data for clinicians/groups that are designated PCMH, PCSP, or APMs.

From our understanding, when a group is PCMH, PCSP, or APM, it does not need to implement Improvement Activities.

The IG references these designations as follows:

• PCMH - Groups can select an IA which indicates that it is a PCMH. Would every PCMH need to implement at least this IA in order to get full IA credit?
• PCSP - is not referenced in the IG at all.
• APM - the IG addresses how to handles submissions to CPC+, but not MIPS.

We are concerned that a group might be construed as not having implemented IAs at all if these designations are not added to the MIPS QRDA III.

Any guidance is much appreciated.