Promoting Interoperability FAQs (2021)

The following questions and responses for the Promoting Interoperability (PI) MIPS performance category are based upon the previous regulation and the 2021 Quality Payment Program (QPP) Final Rule. 

1. How much of the MIPS final score is determined by the PI performance category?
The MIPS Promoting Interoperability (PI) performance category accounts for 25 percent of an eligible clinician’s or group’s MIPS final score. For non-patient-facing eligible clinicians or those who meet the criteria for a different exception for reporting PI, CMS will reweight the 25 percent to other MIPS performance categories.

2. How do I know if I must submit PI data?
Most physician anesthesiologists and their groups will not have to submit data for the MIPS Promoting Interoperability category.  ECs can check their participation status and special status on the QPP website.

ECs and their practices that are designated under the special status categories of non-patient facing, hospital-based or ambulatory surgery center-based are automatically exempt from reporting the PI category. Additional information on special statuses can be found on the ASA and QPP websites as well.

3. My group does not have a special status designation that would exempt us from PI. Are there other avenues to claim an exemption?
Eligible clinicians or groups who do not have an automatic exception via special status may apply for a hardship exception each year, if applicable. There are significant hardship categories that you or your group may apply for on an annual basis. The hardship categories are:

  • Insufficient internet connectivity
  • 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
  • MIPS eligible clinician in a small practice
  • MIPS eligible clinician using decertified EHR technology

For the 2021 performance year, these hardship applications are expected to be due on December 31, 2021.

4. I am exempt from PI but I’d like to participate. Can I participate?
Eligible clinicians and their groups can opt-in to participate in PI. However, if you submit any data for PI, you will be assessed and scored by CMS. 

5. Can I participate in PI via group reporting?
Yes, individual eligible clinicians can elect to participate in PI as a part of a group. To participate in MIPS a group must aggregate their performance data of all the MIPS eligible clinicians in the group’s TIN for whom the group has data in CEHRT.

6. Can my group report PI data to the Anesthesia Quality Institute?
Yes, the Anesthesia Quality Institute is accepting PI data for the 2021 performance year. Individuals and groups that wish to submit PI data external to AQI can complete their submission via the CMS Quality Payment Program webpage or through another third-party vendor. 

7. What type of certified EHR technology (CEHRT) do I need to participate?
For 2021, eligible clinicians and groups must use an Electronic Health Record (EHR) that meets the 2015 Edition certification criteria, 2015 Edition Cures Update certification criteria, or a combination of both for participation in this performance category. The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology where ECs can check their CEHRT.