MIPS: Promoting Interoperability (PI)

MIPS Payment Track:

Promoting Interoperability Performance Category

PI and Patient Portals

Watch as Steven Waldren, MD, discusses the PI (formerly known as ACI) requirement to engage patients using a patient portal.

Explaining the Promoting Interoperability Category*

Under the Medicare Access and CHIP Reauthorization Act (MACRA), which was passed and signed into law in April 2015, eligible clinicians (ECs) will participate in either the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (AAPM). MIPS and AAPMs are collectively referred to as the Quality Payment Program (QPP).

With the MIPS track, ECs receive a final score based on performance in four performance categories: quality, cost, promoting interoperability (PI), and improvement activities.

*This category was formerly called advancing care information (ACI).

Promoting Interoperability (PI) Reporting

The Centers for Medicare & Medicaid Services (CMS) updated the reporting requirements for the promoting interoperability (PI) category beginning with the 2019 performance year. Eligible clinicians must report on a set of required measures and will be scored based on their performance on the measures. Failure to report any one of the measures will result in a score of zero for the entire PI performance category. ECs must report a minimum of 90 consecutive days for the PI category. The PI category makes up 25 percent of the MIPS final score.

Eligible clinicians can report using a qualified registry, qualified clinical data registry (QCDR), electronic health record (EHR), or through attestation.

  • Clinicians can only use one reporting method per performance category (i.e., you cannot report the PI category using an EHR and via attestation).
  • If choosing to report as a group, all performance categories must be reported as a group and will be scored as a group.

Eligible clinicians must use 2015 Edition CEHRT for the PI performance period (90 consecutive days).  ECs can use the Certified Health IT Product List(chpl.healthit.gov) to review if their EHR is certified.

Eligible clinicians without an EHR are eligible to participate in MIPS, but they will not be eligible for any of the points in the PI category.

Promoting Interoperability Scoring

The PI category score is based on a clinician's (or group's) performance on a set of required measures. Each measure contributes a different weight to the performance category score.

Note: Failure to report any of the required measures will result in a PI performance category score of zero.

There are no thresholds within the PI category, meaning a clinician does not need to report a certain number or percent of patients to receive points in the category. Clinicians are scored based on their individual performance. The following table lists the required PI measures and their corresponding weight.

ObjectiveWeightMaximum Points
Objective: e-prescribing
Weight: e-Prescribing**Maximum Points: 10 points
Objective: Bonus: Query of Prescription Drug Monitoring Program (PDMP)Weight: 5 bonus points
Objective: Bonus: Verify Opioid Treatment Agreement*Weight: 5 bonus points
Objective: Health Information ExchangeWeight: Support Electronic Referral Loops by Sending Health Information**Maximum Points: 20 points
Objective: Support Electronic Referral Loops by Receiving and Incorporating Health Information**
Weight: 20 points
Objective: Provide to Patient Exchange
Weight: Provide Patients Electronic Access to Their Health Information
Maximum Points: 40 points
Objective: Public Health and Clinical Data Exchange

Report to two different public health agencies or clinical data registries for any of the following:


Immunization registry reporting**


Electronic case reporting**


Public health registry reporting**


Clinical data registry reporting**


Syndromic surveillance reporting**

Maximum Points: 10 points

*Required beginning in 2020
**Exclusions available

Please note: CMS has changed the name and combined some of the measures. However, the requirements for the measures remain similar. Detailed measure specifications and exclusions can be found on the CMS QPP website(qpp.cms.gov).

Hardship Exceptions

Eligible clinicians who have faced significant hardships can apply for an exception. The exception will reassign the PI category weight (25%) to the quality performance category.

To qualify for a significant hardship exception, an EC must have experienced one of the following during the reporting period:

  • Insufficient internet connectivity (based on the Federal Communications Commission’s National Broadband Map(broadbandmap.fcc.gov);
  • Extreme or uncontrollable circumstances (such as natural disaster or significant issues related to CEHRT);
  • Lack of control over the availability over CEHRT (control does not mean final decision-making authority or practicing as part of a group); and/or
  • Lack of face-to-face interaction (for ECs who are non-patient facing);

Small practices may also apply for an exception if they faced hardships in acquiring CEHRT.

Attestation Information

In addition to reporting on measures, clinician’s must also attest to several statements to receive points in the PI category. These attestations are related to provisions that:

  • Allow the Office of the National Coordinator (ONC) to review the performance of health information technology (HIT), referred to as “direct review,” and
  • Ensure clinicians do not engage in activities that would knowingly or willfully prevent or obstruct the electronic exchange of information (known as “information blocking”) within their certified electronic health record technology (CEHRT)

Clinicians will follow the instructions of their selected reporting method to attest.

Direct Review

Clinicians must attest they are aware of the requirement to cooperate in good faith with ONC direct review of their HIT if a request is received. If a request has been received, clinicians must also attest that they did cooperate in ONC direct review.

Direct review of HIT allows the ONC to evaluate the performance of certified HIT in certain circumstances, including in response to problems and complaints with the performance of CEHRT.

To cooperate in good faith means the clinician responds in a timely manner to requests for information and accommodating requests by ONC to access the clinician’s CEHRT. It is expected that ONC will work to accommodate a clinician’s schedule and other circumstances when requesting information. ONC predicts that a very small percentage of ECs will be asked to participate in direct review.

Information Blocking

Clinicians must attest to three statements declaring they did not knowingly or willfully limit the electronic exchange of information.

The first statement attests that the clinician did not take actions to limit or restrict the compatibility or interoperability of CEHRT. This includes actions such as purposefully disabling certain functionalities within the CEHRT.

The second statement is related to the implementation of CEHRT and attests that the clinician implemented technology, standards, and workflows that ensured the CEHRT was connected according to applicable law, compliant with information exchange standards, allowed patients timely access to electronic health information, and allowed the timely bi-directional exchange of information with other health care providers.

The third statement is related to how the clinician used CEHRT during the reporting period and attests that the clinician responded in a timely manner to requests to retrieve or exchange electronic health information with patients and other health care providers, regardless of the requestor’s affiliation.

Last updated: February 2019