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Most of the providers have heard about QPP and MIPS and its elements, for sure. And you know that reporting this year will affect your payment in 2020. To take care of your future, you need to do something today. But WHAT to do? This could be still a bit unclear for many due to extensive description of the program and its requirements, due to complexity and interconnections. And renaming of the categories does not help people to figure out what is what. By this short article we will enlighten a part of the program, which perhaps will clarify the situation.   


The category Advancing Care Information (ACI) was renamed by CMS to Promoting Interoperability (PI) in order to focus on interoperability and improving flexibility. The category itself promotes patient engagement and electronic exchange of health information.

25% of final MIPS score goes to Promoting Interoperability category. The performance data period started at January 1, 2018 and continuous until December 31, 2018 and remember that your performance with MIPS in 2018 impacts your 2020 Medicare reimbursement. Everyone must start a 90-day reporting period no later than October 2, 2018.  Generally, you must submit your data not later than March 31, 2019. 

Ways of data submission

There are 4 ways participants can submit data:

So, what are the rules and requirements?

Certified electronic heath record technology (CEHRT) is required to report for PI category, unless the provider meets criteria for hardship exception or gets a Special Status. Simple absence of CEHRT does not qualify providers for this exception/status. iSmart EHR is a good assistant for you in MIPS reporting. We have a qualified specialist, who can consult you about reporting details.

There are 2 measure sets for submitting data:

  • Promoting Interoperability Objectives and Measures
  • Promoting Interoperability Transition Objectives and Measures.

The measure set you choose is based on your CEHRT edition. Participants must submit data for 4 or 5 Base score measures, depending on CEHRT edition. This must be done in 90 days during 2018.    

How is PI score calculated?

Promoting Interoperability (PI) consists of two key parts – the Base score and the Performance score. There is also a Bonus score. The sum divided like this:


According to this scheme maximum earned score could be 165%, but any above 100% will be cut. After getting score result within this category, it will be weighted by 25%. For example:

An eligible provider earned base score of 50%, performance score of 40% and got no bonus score.
His overall score for the category is 90%, weighted by 25% - 90 x 0.25 = 22.5 points to final MIPS score
How is the Base score calculated?

There are certain requirements that must be met in order to receive 50% of Base score. If requirements are not met you will get no score for the entire category.  So, what must be done to avoid it? You have to submit “YES” for “Security risk analysis” measure and at least a 1 in the numerator for the numerator/denominator of the remaining measures.

The 5 base score PI measures are:

  1. Security Risk Analysis
  2. e-Prescribing*
  3. Provide Patient Access
  4. Send a Summary of Care*
  5. Request/Accept Summary of Care*

The 4 base score 2018 PI transition measures are:

  1. Security Risk Analysis
  2. e-Prescribing*
  3. Provide Patient Access
  4. Health Information Exchange*

*If you qualify for these exclusions, you can still receive the base score if you:

  • Report a 0 in the numerator/denominator for the applicable measure(s) AND
  • Claim the exclusion through attestation or EHR reporting

If you claim these exclusions, you’ll meet the base score but will receive a 0% performance score for the measure(s). If you report a 0 in the numerator/denominator for these measures without claiming the exclusion, you wouldn’t meet the base score and would receive a 0 for the overall PI performance category score. 

How is the Performance score calculated?

This score calculated on base of the measures reported. Most of the measures worth a maximum of 10%, only 2 worth a maximum of 20%. And there is one type of measures that requires “yes” or “no” as the answer – Public Health and Clinical Data Registry (CDR) Reporting measures. Answer “yes” for one of these measures will give provider full 10%.   

Performance rates for each measure worth up to 10%

Performance rate >0-10 = 1%

Performance rate  51-60 = 6%

Performance rate  11-20 = 2%

Performance rate  61-70 = 7%

Performance rate  21-30 = 3%

Performance rate  71-80 = 8%

Performance rate  31-40 = 4%

Performance rate  81-90 = 9%

Performance rate  41-50 = 5%

Performance rate  91-100 = 10%

How is the Bonus score calculated?

You can earn bonus percentage points:

  • Reporting “yes” for 1 or more additional public health agencies or clinical data registries beyond the one identified for the performance score measure results in a 5% bonus. Like the performance score measure, groups can claim this as long as 1 clinician in the group is actively working with an entity that’s different from what’s reported for the performance score.
  • Reporting “yes” to the completion of at least 1 of the specified Improvement Activities using CEHRT will result in a 10% bonus and submitting that activity for the Improvement Activity performance category. See Appendix B for the list of Improvement Activities that may be completed using CEHRT to qualify for the bonus.
  • Reporting only from the PI Objectives and Measures set (and only using 2015 edition CEHRT) will result in a 10% bonus.
June 2018