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 2024.

Reporting Requirements

To receive credit for the PI component in 2024, clinicians MUST:

Use an EHR that meets the ONC health IT certification criteria
Report their performance for 180 continuous days or more
Submit a "yes" to completing the Actions to Limit or Restrict Compatibility or Interoperability of CEHRT Attestation
Submit a "yes" to ONC Direct Review Attestation (if applicable)
Submit a "yes" to completing the Security Risk Analysis (SRA) measure
Attest "yes" 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 objective, or claim an exclusion, if applicable.

Promoting Interoperability Bonus Points

Clinicians can earn up to 5 bonus points if they submit a “yes” response to one of the optional Public Health and Clinical Data Exchange measures (Public Health Registry Reporting, Clinical Data Registry Reporting, or Syndromic Surveillance Reporting)

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.

Objectives	Measures	Maximum Points	Measurement
Electronic Prescribing	e-Prescribing	10 points	Measurement
	Query of Prescription Drug Monitoring Program	10 Points	Attestation
Health Information Exchange (Option 1)	Enabling Exchange Under TEFCA	30 points	Attestation
Health Information Exchange (Option 2)	Health Information Exchange Bi-Directional Exchange	30 points	Attestation
Health Information Exchange (Option 3)	Support Electronic Referral Loops by Sending Health Information	15 points	Performance
	Support Electronic Referral Loops by Receiving and Reconciling Health Information	15 points	Performance
Provider to Patient Exchange	Provide Patients Access to their Health Information	25 points	Performance
Public Health and Clinical Data Exchange	Electronic Case Reporting	25 points	Attestation
	Immunization Registry Reporting	25 points	Attestation
	Clinical Data Registry Reporting	5 bonus points*	Attestation
	Public Health Registry Reporting	5 bonus points*	Attestation
	Syndromic Surveillance Reporting	5 bonus points*	Attestation

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

Hardship Exceptions (Application Required)

Individuals, groups, and virtual groups may submit a MIPS Promoting Interoperability Hardship Exception application if they can cite one of the following hardships:

MIPS eligible clinician using decertified EHR technology
Insufficient internet connectivity
Extreme and uncontrollable circumstances
Lack of control over the availability of CEHRT

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

If approved for an exception, the PI category will be reweighted to 0 zero percent and the 25 percent will be redistributed to other categories. For more information on applying for the hardship exception, please visit the CMS website.

Special Statuses (No Application Required)

Some clinicians may have a special status designation that qualifies them for automatic reweighting of the PI category. For 2024, these clinicians are those based at ambulatory surgery centers, hospitals, and small practices, or those who are non-patient facing.

If a clinician is reporting as part of a group, virtual group, or APM, it is important to note that all MIPS eligible clinicians in the group must qualify for reweighting in order for the group to be reweighted.

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.