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PI Performance Category Requirements

In the MIPS program, the Promoting Interoperability (PI) category replaces the Medicare Electronic Health Records (EHR) Incentive Program (Meaningful Use) and is intended to promote patient engagement and the electronic exchange of information using certified EHR technology (CEHRT). Beginning in 2019, you will submit a single set of Promoting Interoperability Objectives and Measures to align with 2015 Edition CEHRT.  This set includes new and existing Promoting Interoperability performance category measures organized under 4 objectives. Measures are no longer classified as base score or performance score measures.


For Performance Year 2019, 2015 Edition CEHRT is required for participation in this performance category. Participants must submit collected data for certain measures from each of the 4 objectives measures (unless an exclusion is claimed) for 90 continuous days or more during 2019. 

In addition to submitting measures, clinicians must submit a “yes” to:

  • The Prevention of Information Blocking Attestation,

  • The ONC Direct Review Attestation, and;

  • The security risk analysis measure.

  • Hardship Exceptions

A clinician or group participating in MIPS may submit a Promoting Interoperability Hardship Exception Application, citing one of the following reasons for review and approval:

  • MIPS eligible clinician in a small practice

  • MIPS eligible clinician using decertified EHR technology

  • Insufficient Internet connectivity

  • Extreme and uncontrollable circumstances

  • Lack of control over the availability of CEHRT

For clinicians participating in MIPS, getting a hardship exception means that the Promoting Interoperability performance category receives zero weight in calculating your final score and the 25% is reallocated to the Quality performance category. There are some clinicians who will be automatically reweighted based on special status (for example, hospital-based clinicians) or their clinician type (for example, a physical therapist, occupational therapist, or clinical psychologist). These clinicians will not need to submit a Promoting Interoperability Hardship Exception Application. If you're submitting as part of a practice, the whole practice must qualify for some sort of hardship exception for the group to be reweighted.

Qualifying clinicians may choose from a variety of methods for submitting PI measures:

Individual Reporting

Group Reporting

  • Attestation

  • QCDR

  • Qualified Registry

  • EHR Vendor

  • Attestation

  • QCDR

  • Qualified Registry

  • EHR Vendor

  • CMS Web Interface (groups of 25 or more)

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