Understanding the MIPS Promoting Interoperability Category and the Impact on MIPS Scoring

The MIPS Promoting Interoperability (PI) category, which replaced the Meaningful Use program, establishes requirements that promote the electronic exchange of information using certified electronic health record technology (CEHRT). MIPS eligible clinicians and groups are scored on their performance on several PI measures. The last day to start a minimum 90-day reporting period to attest to PI is October 3, 2022. Making sense of all of the requirements can be challenging, so let’s examine how to report the PI category and the potential impact on the MIPS final score.

What's New in 2022?

There were some important changes to the PI category for the 2022 performance year:

• CMS will apply automatic reweighting to clinical social workers and small practices (15 or fewer clinicians) beginning with the 2022 performance year. This means PI will be automatically reweighted to 0%.
• The Public Health and Clinical Data Exchange objective is revised to support public health agencies (PHAs) in future health threats and a long term COVID-19 recovery:
  • CMS will require reporting of the 1) Immunization Registry Reporting and 2) Electronic Case Reporting (unless an exclusion can be claimed).
    •  A 4th exclusion for the Electronic Case Reporting measure was added for 2022 only. The exception applies if the clinician uses CEHRT that isn’t certified to the electronic case reporting certification criterion prior to the start of the performance period they select in 2022.
  • Clinicians can optionally report on 1) The Public Health Registry Reporting 2) Clinical Data Registry Reporting or 3) Syndromic Surveillance Reporting for 5 bonus points. Reporting more than one of these optional measures won’t result in more than 5 bonus points. 
• A new required (but unscored) attestation was added called the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides). This measure requires clinicians to attest to conducting an annual assessment of the SAFER Guides beginning with the 2022 performance period.
• The Prevention of Information Blocking attestation statements were updated to distinguish this attestation from the separate information blocking policies established in the 21st Century Cures Act final rule. This attestation has been renamed Actions to Limit or Restrict Interoperability.

CEHRT Required

Attesting to the PI category requires use of CEHRT. MIPS eligible clinicians may use:

• Technology certified to the existing 2015 Edition certification criteria; or 
• Technology certified to the 2015 Edition Cures Update certification criteria; or
• A combination of both to collect and report their PI data and eCQMs for the Quality performance category. 

Clinicians can check their CEHRT status by searching for their EHR product(s) on the Certified Health IT Product List (CHPL) website here.  

PI Reweighting and Exemptions

The PI category is worth 25% of a clinician or group’s total MIPS score and requires a minimum of any continuous 90-day reporting period during the calendar year. Under certain circumstances, CMS will reweight the PI category to 0% and the 25% would be added to other MIPS categories.

Automatic Reweighting

The following list of clinician types will have PI automatically reweighted to 0% and will not have to submit a PI hardship exception application:

• NEW:  Clinical social workers 
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Physical therapists
• Occupational therapists
• Qualified speech-language pathologists
• Qualified audiologists
• Clinical psychologists
• Registered dietitian or nutrition professionals

Clinicians and groups with the following “special status” designations also qualify for automatic reweighting and will not have to submit a PI hardship exception application:

• NEW:  Small practices (15 or fewer clinicians) 
• Ambulatory Surgical Center (ASC)-based:
  • Individual clinicians who furnish 75% or more of their covered professional services in sites of service identified by the Place of Service (POS) code 24. 
  • Groups when 100% of the MIPS eligible clinicians in the group are ASC-based as individuals.
• Hospital-based:
  • Individual clinicians who furnish 75% or more of their covered professional services in a hospital. 
  • Groups when more than 75% of the MIPS eligible clinicians in the group meet the definition of hospital-based as individuals.
• Non-patient facing:
  • Individual clinicians who have 100 or fewer Medicare Part B patient-facing encounters (including telehealth services).
  • Groups when more than 75% of the MIPS eligible clinicians in the group meet the definition of non-patient facing as individuals.

A group also qualifies for automatic reweighting when 100% of the MIPS eligible clinicians in the group qualify for reweighting as individuals for any combination of reasons.

More information on reweighting scenarios can be found here.

Hardship Exceptions

If a clinician or group does not qualify for PI to be automatically reweighted, they can apply to CMS to obtain an exemption from the PI category due to a “significant hardship”. The deadline to submit applications to CMS is December 31, 2022.    

Applications must be based on one of the following reasons:

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

Simply not having 2015 Edition CEHRT does not qualify as a reason for the PI hardship exception.

Important:  MIPS eligible clinicians and groups that qualify for reweighting will be scored in this performance category if they submit any PI data.

PI Objectives and Measures

There is a single set of objectives and measures that will be scored based on a clinician or group’s performance. Data must be submitted for all required measures from each of the objectives (unless an applicable exclusion is claimed) for the same 90 continuous days (or more) during 2022.

More details about what’s required for each of the PI measures can be found here.

Note:  *If a clinician reports MIPS to a registry it does not count towards the Public Health and Clinical Data Exchange objective. Click here for more information on how to engage with MDinteractive’s Clinical Data Registry to ensure PI points can be earned for this measure.

Important:  In addition to reporting on the above measures, clinicians must also report their EHR’s CMS Certification ID code and attest to the following (answer “yes”): 

• The Security Risk Analysis measure;
• The Actions to Limit or Restrict the Compatibility or Interoperability of CEHRT attestation; and
• NEW: The High Priority Practices Guide of the Safety Assurance Factors for EHR (SAFER Guides) measure (can answer "yes" or "no" in 2022).

Scoring Overview

The PI score is the sum of points earned for the submitted measures multiplied by the 25% PI category weight. Clinicians may earn a maximum score of up to 115%, but any score above 100% is capped at 100%. Each PI measure is scored based on the clinician or group’s performance on the measure (e.g., the numerator/denominator submitted or answering “yes,” if applicable).

Performance Score Illustration:

A numerator/denominator of 170/200 for the Provider to Patient Exchange measure (worth up to 40 points) would have a performance rate of 85%. The points for this measure would be calculated as follows:

.85 (performance rate) x 40 (total possible measure points) = 34 points (added to your total PI score)

PI Score Illustration:

If all of the PI measures combined earned 75 points for a clinician, the total PI score would be 18.75 points:

(75 (PI points) x .25 (PI category weight)) x 100 = 18.75 PI points

Important: Since scoring is based on your performance for each measure, earning the full 25 points for PI in your final MIPS score could be more difficult. And, if you do not report a required measure, or claim an exclusion for a required measure, you will receive a total score of 0 for the PI performance category. It is important to pay close attention to your performance on the measures and make improvements where necessary to maximize your PI score and Medicare payment adjustments.

APMs

Individuals and groups in a MIPS Alternative Payment Model (APM) will still report PI data at the individual or group level even if their APM Entity is reporting quality and improvement activity data. Clinicians participating as an APM Entity and reporting traditional MIPS will have the PI category weighted at 30% of their MIPS final score.  

MIPS eligible clinicians and groups participating in a MIPS APM can also apply for Hardship Exceptions and qualify for automatic re-weighting like other MIPS eligible clinicians. However, APM Entities can’t submit a PI Hardship Exception at the entity level. 

PI Checklist

In 2022 small practices will have PI automatically reweighted to 0%. Clinicians planning to attest to PI this year should first ensure they have 2015 Edition CEHRT, 2015 Edition Cures Update CEHRT, or a combination of both. Next they should run a trial report in their EHR of the 2022 PI measures to understand how they are performing in each area since it will impact their total MIPS score. The PI reports can be uploaded to their MDinteractive accounts for review and feedback. We understand this issue is complex, so our MIPS specialists can help answer any questions about the requirements or provide feedback on how clinicians can maximize their MIPS points in this category. 

MACRA MIPS Promoting Interoperability PI Scoring 2015 Edition CEHRT