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Promoting Interoperability

  • What Is Promoting Interoperability?

    MACRA

    The Promoting Interoperability (PI) category of the Merit-Based Incentive Payment System (MIPS) requires physicians to attest annually to meeting certain measures prescribed by the Centers for Medicare and Medicaid Services (CMS). The 2025 performance year impacts Medicare Fee for Service payments in 2027.

    In 2025, performance measurement in the MIPS program are based on four weighted categories.

    • Quality (30%),
    • PI (25%), 
    • Improvement activities (15%), and
    • Cost (30%).
    Learn How MIPS Works

  • How Do I Meet the PI Requirements?

    To meet the requirements of the PI category, an EHR is required.

    • If you do not currently use an EHR, you will have to select, purchase, and implement an EHR. Be sure the product you select is certified. TMA has numerous resources to help practices with selection.
    • If you currently use a certified EHR, check with your EHR vendor to ensure the product you use meets the ONC health IT certification criteria. View the list of certified products here.

  • 2025 PI Objectives and Measures

    For 2025, eligible clinicians must use technology that meets the ONC health IT certification criteria.

    Participants must submit collected data for certain measures from each of the measures (unless an exclusion is claimed) for 180 continuous days or more during 2025. 

    In addition to submitting data on the measures, clinicians must positively attest to:

    • View the 2025 measures at-a-glance.

    • Additional information and measure specifications may be found on the Quality Payment Program’s Promoting Interoperability page.

    • MIPS Eligible clinicians and groups with the following special statuses are exempt from reporting Promoting Interoperability data:

      • Ambulatory surgical center-based
      • Hospital-based
      • Non-patient facing
      • Small practice (15 or fewer clinicians bill under the practice’s TIN)

      Individuals and groups can request exemption from reporting Promoting Interoperability data by submitting a hardship exception application citing one of the reasons for review and approval:

      • MIPS eligible clinician using decertified technology (under the ONC Health IT Certification Program)
      • Insufficient internet connectivity
      • Extreme and uncontrollable circumstances
      • Lack of control over the availability of certified electronic health record technology

  • Resources for Objectives and Measures

    Use the following resources to meet the PI objectives and measures. 

    E-prescribing

    Health Information Exchange

    Provider to Patient Exchange

    Public Health and Clinical Data Exchange

    Security Risk Analysis

  • Reporting Options

    Notes: 

    • Be sure to ask your EHR vendor about MIPS reporting options.
    • You don’t have to use the same reporting mechanism for all MIPS categories. For example, you can report PI via attestation, but submit quality measures via a qualified registry. 
    • When using the Group Reporting option, you must use the same identifier for all reporting methods. For example, you cannot individually report PI and then group report quality measures.

  • Don't Forget About Audits

    CMS could tap you for a MIPS audit in the future. Here are some things to know to prepare your practice.

    • Document everything (take screen shots)
    • Maintain documentation for 6 years
    • Maintain practice email addresses for notification
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