American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

Reporting for Promoting Interoperability

Promoting Interoperability 25%

The Promoting Interoperability (PI; formerly the Advancing Care Information) component is worth 25 percent of the Merit-based Incentive Payment System (MIPS) Final Score. The PI category has undergone a major overhaul in 2019. MIPS-eligible clinicians will now be scored solely on performance, which contrasts with previous years where the category’s score was composed of three parts: a base score, performance score, and bonus score.

To receive credit for the PI component in 2019, clinicians MUST:

  • Submit their data using 2015 edition certified electronic health record technology (CEHRT)
  • Report their performance for a minimum of a continuous 90-day period
  • Submit a “yes” to completing the Prevention of Information Blocking Attestations
  • Submit a “yes” to ONC Direct Review Attestation (if applicable)
  • Submit a “yes” to completing the Security Risk Analysis (SRA) measure*
  • Report on ALL the required measures under each objective or claim an exclusion, if applicable

*In 2019, the SRA will no longer be scored as a measure, but completion is required to receive a score in this category. The Office of the National Coordinator for Health IT (ONC) Office for Civil Rights has many resources on how to fulfill the Security Risk Analysis.

A surgeon who meets all the requirements for this category can receive a maximum score of 100 points. Surgeons can also earn up to 5 bonus points each when they submit data on two optional measures—Query of PDMP and Verify Opioid Treatment Agreement— under the e-Prescribing objective.



Maximum Points



10 points

Query of Prescription Drug Monitoring Program (PDMP)

5 bonus points

Verify Opioid Treatment Agreement

5 bonus points

Health Information Exchange

Support Electronic Referral Loops by Sending Health Information (formerly Send a Summary of Care)

20 points

Support Electronic Referral Loops by Receiving and Incorporating Health Information

20 points

Provider to Patient Exchange

Provide Patients Electronic Access to their Health Information (formerly Provide Patient Access)

40 points

Public Health and Clinical Data Exchange

Choose two registries:

  • Immunization Registry Reporting
  • Electronic Case Reporting
  • Public Health Registry Reporting
  • Clinical Data Registry Reporting
  • Syndromic Surveillance Reporting

10 points

Additional information about these measures, including applicable exclusions, is available for download on the Quality Payment Program (QPP) website.

2019 Promoting Interoperability Scoring Example

Providers may meet criteria for exceptions from the PI component entirely. The Centers for Medicare and Medicaid Services (CMS) will reweight the PI component to 0 percent and reallocate its weight (25 percent) to the Quality component for surgeons who meet one of the following criteria:

  • Small practice clinicians (solo practitioners or clinicians in groups with 15 or fewer eligible clinicians)
  • Hospital-based MIPS-eligible clinicians
  • Ambulatory surgical center (ASC)-based MIPS-eligible clinicians (Please note: This policy was finalized to begin starting in 2017.)
  • MIPS-eligible clinicians whose EHR was decertified during the performance year or the year before the current performance year
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

Providers can determine if they are classified as a small practice or are considered hospital-based by using the MIPS Participation Status tool. Providers that are hospital-based or ASC-based are automatically exempt from the PI category and will receive an automatic reweighting of the category. Providers that are a small practice or whose EHR was decertified must apply for a hardship exception through the Hardship Application.

CMS also offers many resources on their QPP website, and is a great resource for learning about and selecting Quality measures, Promoting Interoperability measures, and Improvement Activities for reporting in 2019.