American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

Promoting Interoperability Performance Category

Promoting Interoperability 25%

The Promoting Interoperability (PI; formerly the Advancing Care Information) component is worth 25 percent of the Merit-based Incentive Payment System (MIPS) Final Score. The PI category underwent only minor changes in 2020.

To receive credit for the PI component in 2020, clinicians MUST:

  • Use 2015 edition-certified electronic health record technology (CEHRT)
  • Report their performance for 90 continuous days or more
  • Submit a “yes” to completing the Prevention of Information Blocking Attestations
  • Submit a “yes” to ONC Direct Review Attestation (if applicable)
  • Submit a “yes” to completing the Security Risk Analysis (SRA) measure*
  • Report data for ALL measures under each of the 4 objectives, or claim an exclusion, if applicable

*In 2020, the SRA will again not be scored as a measure, but completion remains required to receive a score in this category. The Office of the National Coordinator for Health IT (ONC) Office for Civil Rights has many resources on how to fulfill the Security Risk Analysis.

A surgeon who meets all the requirements for this category can receive a maximum score of 100 points. Surgeons can also earn up to 5 bonus points each when they submit data on two optional measures—Query of Prescription Drug Monitoring Program (PDMP)—under the e-Prescribing objective.

Please note: In order to receive any points in the PI category, you must submit numerator and denominator data for EVERY required measure.



Maximum Points



10 points

Query of Prescription Drug Monitoring Program

5 bonus points

Health Information Exchange

Support Electronic Referral Loops by Sending Health Information **(formerly Send a Summary of Care)

20 points

Support Electronic Referral Loops by Receiving and Incorporating Health Information**

20 points

Provider to Patient Exchange

Provide Patients Electronic Access to Their Health Information (formerly Provide Patient Access)

40 points

Public Health and Clinical Data Exchange

Choose two registries:

  • Immunization Registry Reporting**
  • Electronic Case Reporting**
  • Public Health Registry Reporting**
  • Clinical Data Registry Reporting**
  • Syndromic Surveillance Reporting**

10 points

**Possible exclusion available for this measure

Providers may be exempt from the PI component completely if they are approved for a hardship exception or meet the definition of a special status category. In these instances, the Centers for Medicare and Medicaid Services (CMS) will reweight the PI component to 0 percent and reallocate its weight (25 percent) to the Quality component. Please note: Clinicians must apply for a hardship exception, while the special status exceptions are applied automatically (no application is required). 

Hardship Exceptions (Application Required)

  • Small practice clinicians (solo practitioners or clinicians in groups with 15 or fewer eligible clinicians)
  • MIPS-eligible clinicians using decertified EHR technology
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT
  • Insufficient Internet connectivity

Special Status Category (No Application Required)

  • Hospital-based MIPS-eligible clinicians

In 2020, the definition of hospital-based was changed, so that group practices can more easily qualify for this automatic exception. To qualify as a hospital-based group in 2020, more than 75 percent of the NPIs in the group must meet the definition of a hospital-based MIPS eligible clinician (that is, the clinician furnishes 75 percent or more of his/her services in a hospital setting). We encourage you to check your status using the Participation Status tool linked below, even if your group practice did not qualify for this exception in prior-years. 

Providers can determine if they are classified as a small practice or are considered hospital-based by using the MIPS Participation Status tool.

CMS also offers many resources on their QPP website, and is a great resource for learning about and selecting Quality measures, Promoting Interoperability measures, and Improvement Activities for reporting in 2020. Please contact Molly Murray at with any questions.