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 2022.

To receive credit for the PI component in 2022, clinicians MUST:

• Use an EHR that meets the 2015 edition-certified electronic health record technology (CEHRT) criteria, 2015 Edition Cures Update certification criteria, or a combination of both.
• 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
• 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 10 bonus points are available for those who submit data for the Query of Prescription Drug Monitoring Program (PDMP) measure under the e-Prescribing objective.
• 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 20 points each or attest to the new "Health Information Exchange Bi-Directional Exchange" measure for a total of 40 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

See the attachment below for more information on how to apply for a 2022 MIPS exception:

How to Apply for a 2022 MIPS Exception

Hospital-Based MIPS-Eligible Clinicians

To qualify as a hospital-based group, 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 furnished 75 percent or more of his/her services in a hospital setting).

Small Practices

Beginning in 2022, those that meet the criteria for the small practice designation will no longer have to submit a hardship application to reweight the PI performance category. If no data are submitted by or on behalf of the small practice for the PI category at the end of the performance period, CMS will automatically reweight the PI category to 0 percent and redistribute its weight to another performance category or categories. If the small practice does submit data for the PI category during the performance year, the data will be scored the same as all other MIPS-eligible clinicians.

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.