Promoting Interoperability Performance Category

The Promoting Interoperability (PI) performance category is worth 25 percent of the Merit-based Incentive Payment System (MIPS) final score in 2023.

To receive credit for the PI component in 2023, clinicians MUST:

• Use an EHR that meets the 2015 Edition Cures Update certification electronic health record technology (CEHRT) criteria
• Report their performance for 90 continuous days or more
• Submit a "yes" to completing the Actions to Limit or Restrict Compatibility or Interoperability of CEHRT (previously named the Prevention of Information Blocking) Attestation
• Submit a "yes" to Office of the National Coordinator for Health Information Technology (ONC)  Direct Review Attestation (if applicable)
• Submit a "yes" to completing the Security Risk Analysis (SRA) measure
• Attest "yes" or "no" to conducting an annual assessment of the High Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides)
• Report data for ALL measures under each of the four objectives, or claim an exclusion, if applicable.

Up to 5 bonus points are available for those who report on the optional registry/syndromic surveillance measures under the Public Health and Clinical Data Exchange objective.

CMS offers an alternative reporting option to meet the requirements of the Health Information Exchange (HIE) objective. You may choose to report the original "Support Electronic Referral Loops by Sending Health Information" and the "Support Electronic Referral Loops by Receiving and Reconciling Health Information" for 15 points each or attest to the new "Health Information Exchange Bi-Directional Exchange" measure for a total of 30 points.

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

*Reporting on more than one of these optional measures will not result in more than 5 bonus points.

Some clinicians/groups may be exempt from the PI component completely if they submit an application and are approved for a Promoting Interoperability hardship exception or meet the definition of a special status category. In these instances, the CMS will reweight the PI component to 0 percent and reallocate its weight to another performance category.

Below are the circumstances for which a PI Hardship Exception can be submitted.

• MIPS-eligible clinicians using decertified EHR technology
• Extreme and uncontrollable circumstances
• Lack of control over the availability of CEHRT
• Insufficient Internet connectivity

The MIPS PI Hardship Exception application period will open in the spring of 2023 and applications will be accepted through 8 p.m. ET on January 2, 2024.

How to Apply for a 2023 MIPS Exception

Special Statuses (No application required)

Clinicians, groups, virtual groups, and APM Entities who meet the requirements for the below special statuses are automatically exempt from reporting PI data for the 2023 performance year:

• Ambulatory surgical center (ASC)-based clinicians – The MIPS eligible clinician furnishes 75% or more of their covered professional services in sites of service identified by Place of Service (POS) code 24 (ambulatory service center).
• Hospital-based clinicians – The MIPS eligible clinician furnishes 75% or more of their covered professional services in a hospital setting as identified by Place of Service (POS) Codes 19, 21, 22, and 23.
• Non-patient-facing clinicians – The MIPS eligible clinician has 100 or fewer Medicare Part B patient-facing encounters (including telehealth services).
• Clinicians in a small practice – The MIPS eligible clinician is one of 15 or fewer clinicians billing under the practice’s TIN.

To find out if you or your group qualify for a special status, use the participation status look-up tool available on the QPP webpages.