2019 MIPS Promoting Interoperability FAQs 


What is the Promoting Interoperability (PI) Performance Category?

This performance category was created by CMS for MIPS to support broad aims within healthcare including care coordination, beneficiary engagement, population management, and health equity, clinicians are rewarded for activities that improve clinical practice, such as shared decision making and increasing access. The Promoting Interoperability (PI) category transitioned from the Medicare Electronic Health Record (E.H.R.) Incentive Program, also known as Meaningful Use, and its purpose is to promote patient engagement and the electronic exchange of health information.

Additional information about MIPS reporting is available in the 2019 MIPS Executive Summary.

For 2019, the PI category is weighted at 25% of the total MIPS score.

Am I required to participate and report for the MIPS PI Category?

Reporting PI data is voluntary for CRNAs. CMS lists them among clinicians (such as nurse practitioners and non-patient-facing physicians) subject to the automatic re-weight to the Quality category.

If I choose to participate in the PI Category, what do I need to report?

Clinicians who choose to PI measures must use 2015 edition certified E.H.R. technology (CEHRT) and collect data for all patients a minimum continuous 90-day period during the performance year. Providers select applicable measures from four objectives: e-Prescribing, Health Information Exchange, Provider-to-Patient Exchange, Public Health and Clinical Data Exchange. Details about the PI measures can be found in the 2019 PI Measure Specifications.

Additionally, ECs must answer "Yes," to the Security Risk Analysis and these attestations:

  • Prevention of Information Blocking
  • Office of National Coordinator (ONC) Direct Review Attestation

For ECs who select the Public Health and Clinical Data Exchange measures, they must participate in two different registries to receive a score.

  • There are hardship exceptions to reporting the PI category
  • Insufficient internet connectivity
  • Extreme or uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • Use of decertified (no longer meet CEHRT criteria) health information technology
  • Small practice

Individual clinicians or groups must apply for a hardship exception in 2019 by December 31, 2019.

What is the reporting period for the PI category?

PI data must be collected for a minimum of a continuous, 90-day period during the calendar year. For Year 3 of the MIPS program the performance period is from January 1, 2019 through December 31, 2019.

How is PI data submitted?

PI data can be submitted using the following submission types:

How is the PI Performance Category scored?

Measure achievable points are between 1 and 10 per measure. ECs can earn up to 100 points for the PI measure set. They can also earn 5 bonus points for optional PI measures:

  • Query of Prescription Drug Monitoring Program (PDMP)
  • Verify Opioid Treatment Agreement

Since the PI category is weighted at 25%, ECs could earn a maximum of 25 points towards the MIPS final score. If a group practice reports PI, data for each EC in the group should be combined under the TIN. Group practices can include clinicians that are eligible for re-weight.

Where can I get additional information about PI Measures?

CRNAs can contact the Quality Payment Program by calling 1-866-288-8292 (TTY 1-877-715-6222), Monday through Friday from 8:00am to 8:00pm EST, or e-mail: QPP@cms.hhsgov. The QPP Resource Library contains the Promoting Interoperability Fact Sheet. There is also a page for clinicians who need Technical Assistance.