Posted on August 24, 2021
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. 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 2021?
There were few changes to the PI category for the 2021 performance year:
- The Query of Prescription Drug Monitoring Program (PDMP) measure will remain as an optional measure, but the bonus points are increased from five points to 10 points.
- The name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information is changed to Support Electronic Referral Loops by Receiving and Reconciling Health Information.
- A new optional Health Information Exchange (HIE) bidirectional exchange measure is added as an alternative reporting option to the two existing measures under the HIE objective.
- CMS updated the CEHRT requirements in response to the ONC 21st Century Cures Act Final Rule.
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. Attesting to the PI category requires the use of CEHRT. MIPS eligible clinicians may use:
- Technology certified to the existing 2015 Edition certification criteria;
- 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.
For clinicians selecting the last continuous 90 days in 2021 (October 3rd - December 31, 2021) as their performance period:
- The 2015 Edition and/or 2015 Edition Cures Update functionality will need to be in place by October 3rd, 2021.
- The 2015 Edition and/or 2015 Edition Cures Update Certification will need to be obtained by December 31, 2021.
Clinicians can check their CEHRT status by searching for their EHR product(s) on the Certified Health IT Product List (CHPL) website here.
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. All measures are required from each of the 4 objectives (except for the bonus measures) unless an exclusion is claimed.
*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
More details about what’s required for each of the PI measures can be found here.
Important: In addition to reporting on the above measures, clinicians must also report their EHR’s CEHRT identification code and attest (answer “yes”) to the following:
- Completing a Security Risk Analysis;
- The Prevention of Information Blocking Attestation; and
- The ONC Direct Review Attestation.
The PI performance category is worth 25% of a clinician or group’s total MIPS score. They may earn a maximum score of up to 110%, 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). The PI score is the sum of points earned for the submitted measures multiplied by the 25% PI category weight.
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.
PI Reweighting and Exemptions
Under certain circumstances, CMS will reweight the PI category to 0% and the 25% would be added to the Quality score.
If a clinician qualifies for a certain “Special Status” or is a certain type of clinician, the PI category will be automatically reweighted to 0%. These clinicians do not need to submit a Quality Payment Program hardship exception application if they qualify for automatic reweighting.
The following list of clinicians would have PI automatically reweighted and would not have to submit a PI Hardship Exception Application:
Ambulatory Surgical Center (ASC)-based
Clinical nurse specialists
Certified registered nurse anesthetists
Qualified speech-language pathologists
Registered dietitian or nutrition professionals
*Groups designated as non-patient facing or hospital-based are automatically eligible to have PI reweighted to zero percent. They are designated as a non-patient facing group or a hospital-based group when more than 75% of the MIPS eligible clinicians in the group meet the definition of non-patient facing or hospital-based as individuals.
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”. Clinicians in a small group (15 or fewer clinicians) can apply for the PI Hardship Exception directly in their MDinteractive accounts. The deadline to submit applications to CMS is December 31, 2021.
Applications must be based on one of the following reasons*:
- MIPS eligible clinician in a small practice (15 or fewer providers in the TIN)
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
- EHR Decertification
Important: MIPS eligible clinicians and groups that qualify for reweighting will be scored in this performance category if they submit any PI data.
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 final 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.
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 2021 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. If a clinician’s EHR is unable to run these reports consider applying for a PI Hardship Exception to have PI reweighted to the Quality Category.
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