Promoting Interoperability FAQs

The following questions and responses for the Promoting Interoperability (PI) MIPS component are based upon the CMS Final MACRA Rule and the CY 2018 updates to the QPP Final Rule.

PI accounts for 25 percent of an eligible clinician’s MIPS Composite Score. For non-patient-facing eligible clinicians or those who meet the criteria for another exception, CMS will reweight the 25 percent to other MIPS performance categories.

Not all physician anesthesiologists must participate in the Promoting Interoperability component of MIPS. There are several steps to determine whether an eligible clinician must attest.

First, there are several hardships exception categories that, if granted, automatically exempt a MIPS-eligible clinician from reporting the PI component. CMS calls these exceptions “Special Status” and they are evaluated annually. ECs can check their participation status on the QPP MIPS Participation Status website.

Eligible clinicians should review their Special Status on the QPP MIPS Participation Status website to determine whether they are hospital-based. Hospital-based MIPS eligible clinicians are those who furnish 75 percent or more of their covered professional services in sites identified with Place of Service (POS) Codes 19 (Off campus outpatient hospital), 21 (Inpatient Hospital), 22 (On campus outpatient hospital), or 23 (Emergency room). If CMS determines the ECs are hospital-based, no participation in PI is required.

Additionally, attestation requirements depend on whether a clinician is non-patient facing. This category is based upon the types of services that an eligible clinician bills. If CMS determines the ECs are non-patient facing, no participation in PI is required.

There is also an exception for Ambulatory Surgery Center-based eligible clinicians. CMS defines this as a MIPS eligible clinician who furnishes 75 percent or more of his or her covered professional services in sites of service identified by POS 24.

Eligible clinicians who do not have an automatic exception may apply for a hardship exception, if applicable. There are significant hardship categories that your facilities may apply for on an annual basis. The hardship categories are:

  • Insufficient Internet Access (Practicing in an area without sufficient Internet access or facing insurmountable barriers to obtaining infrastructure, such as a lack of broadband access)
  • Extreme and Uncontrollable Circumstances (Natural disasters, practice or hospital closure, severe financial distress, EHR certification/vendor issues).
  • Lack of Control over the Availability of CEHRT (Inability to control CEHRT availability in over 50% of patient encounters)

In 2018, CMS finalized a Small Practice exception which excepts eligible clinicians who are part of a practice with 15 or fewer clinicians. This exception requires ECs to submit an application. For the 2018 performance year, these hardship applications are due on December 31, 2018.

Eligible clinicians can participate but note that if you do participate, you will be assessed and scored by CMS. If the eligible clinician does not meet the PI base requirements, they will receive a 0 for the PI performance category.

Eligible clinicians must successfully attest to all base measures to receive any score. If you do not successfully attest to the base score measures, you will receive a 0 for the PI component of MIPS. Therefore, an EC must successfully attest to the base score and then successfully attest to any number of additional measures in the performance score and bonus points to make up an additional 50%. An eligible clinician who successfully attests and/or receives the highest score in the performance and bonus categories for ALL available measures could receive a score of 165%, however, the maximum allowed score is 100%. An EC or group that receives 100 percent would be awarded the full 25 points toward their MIPS total score.

For more information on scoring, check our MACRA PI Scoring page for 2018.

ASA has compiled a list of resources related to the implementation of electronic health records.

For the 2018 performance period MIPS eligible clinicians can use EHR technology certified to the 2014 Edition, a combination of both 2014 and 2015 Editions, or the 2015 Edition.

If a MIPS eligible clinician switches from 2014 Edition to 2015 Edition CEHRT during the performance period, the data collected for the base and performance score measures should be combined from both the 2014 and 2015 Edition of CEHRT.

The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology. As more versions of 2015 CEHRT become available, ONC will update this resource for those seeking to make EHR purchasing decisions. For additional questions, ONC can be reached by e-mail or by phone at (202) 690-7151.

Yes. If you choose to engage in group reporting, CMS will assess your group across all four MIPS performance categories.

If you are reporting as an individual, eligible clinicians may report via Attestation, a QCDR, a Qualified Registry, or your EHR. If you are engaging in group reporting, you may report under each of the previously listed options in addition to the CMS Web Interface for groups of 25 or more.