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

Promoting Interoperability Performance Category

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 underwent only minor changes in 2021.

To receive credit for the PI component in 2021, clinicians MUST:

  • Use an EHR that meets the 2015 edition-certified electronic health record technology (CEHRT) criteria, 2015 Edition Cures Update certification criteria, or a combination of both. 
  • Report their performance for 90 continuous days or more
  • 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 data for ALL measures under each of the 4 objectives, or claim an exclusion, if applicable

*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 Prescription Drug Monitoring Program (PDMP)—under the e-Prescribing objective.

New in 2021: CMS offers an alternative reporting option to meet the requirements of the Health Information Exchange (HIE) objective. Beginning in 2021, you may choose to report the original “Support Electronic Referral Loops by Sending Health Information” and the “Support Electronic Referral Loops by Receiving and Reconciling Health Information” for 20 points each or attest to the new “Health Information Exchange Bi-Directional Exchange” measure for a total of 40 points.

Please note: In order to receive any points in the PI category, you must submit numerator and denominator data for EVERY required measure.



Maximum Points




10 points


Bonus: Query of Prescription Drug Monitoring Program

10 bonus points


Health Information Exchange (OPTION 1)

Support Electronic Referral Loops by Sending Health Information **

20 points


Support Electronic Referral Loops by Receiving and Incorporating Health Information**

20 points

Health Information Exchange (OPTION 2) Health Information Exchange (HIE) Bi-Directional Exchange 40 points Attestation

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


**Possible exclusion available for this measure

Providers may be exempt from the PI component completely if they are approved for a Promoting Interoperability hardship exception or meet the definition of a special status category. In these instances, the CMS will reweight the PI component to 0 percent and reallocate its weight (25 percent) to the Quality component. Please note: Clinicians must apply for a PI hardship exception, while the special status exceptions are applied automatically (no application is required). See the MIPS Hardships Exceptions page more details on submitting PI and Extreme and Uncontrollable Circumstances Hardship Exception applications.

Hardship Exceptions (Application Required)

  • Small practice clinicians (solo practitioners or clinicians in groups with 15 or fewer eligible clinicians)
  • MIPS-eligible clinicians using decertified EHR technology
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT
  • Insufficient Internet connectivity

Special Status Category (No Application Required)

  • Hospital-based MIPS-eligible clinicians

To qualify as a hospital-based group, more than 75 percent of the NPIs in the group must meet the definition of a hospital-based MIPS eligible clinician (that is, the clinician furnishes 75 percent or more of his/her services in a hospital setting). We encourage you to check your status using the Participation Status tool linked below, even if your group practice did not qualify for this exception in prior-years. /em>

Providers can determine if they are classified as a small practice or are considered hospital-based by using the MIPS Participation Status tool.

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 2021. span>Please contact Haley Jeffcoat at with any questions.