Overview
This performance category promotes patient engagement and electronic exchange of information using (CEHRT).
New: Medicare Shared Savings Program (Shared Savings Program) Requirement to Report the MIPS Promoting Interoperability Performance Category
Unless excluded, for performance years beginning on or after January 1, 2025, an Accountable Care Organization (ACO) participant, ACO provider/supplier, and ACO professional that is a MIPS eligible clinician, Qualifying APM Participant (QP), or Partial Qualifying APM Participant (Partial QP) must:
- Report the MIPS Promoting Interoperability performance category measures and requirements to MIPS at the individual, group, virtual group, or APM Entity level (i.e., ACO reports on behalf of its clinicians); and
- Earn a performance category score for the MIPS Promoting Interoperability performance category at the individual, group, virtual group, or APM Entity level.
This requirement applies regardless of the Shared Savings Program track in which the ACO participant, ACO provider/supplier, or ACO professional participates. Review Frequently Asked Questions on the Shared Savings Program Requirement to Report Objectives and Measures for the MIPS Promoting Interoperability Performance Category (PDF) for more information.
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Performance Year
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2024 Performance Year Promoting Interoperability Requirements
30% OF FINAL SCORE
This percentage can change due to special statuses, an approved hardship exception application, or reweighting of other performance categories.
What Promoting Interoperability Data Should I Submit?
You'll submit a single set of Promoting Interoperability objectives and measures organized under several objectives.
Requirements
For the 2024 performance year, you’re required to use an Electronic Health Record (EHR) that meets the certification criteria at 45 CFR 170.315 for participation in this performance category to align with the Office of the National Coordinator for Health Information Technology (ONC)’s current and future regulation.
Beginning with the 2024 performance period, you must submit collected data for the required measures in each objective (unless an applicable exclusion is claimed) for the same 180 continuous days (or more) during the calendar year.
In addition to submitting measures, you must provide your EHR’s CMS identification code from the Certified Health IT Product List (CHPL) and submit a “yes” to:
- The Actions to Limit or Restrict Compatibility or Interoperability of CEHRT (previously named the Prevention of Information Blocking) Attestation.
- The ONC Direct Review Attestation.
- The Security Risk Analysis Measure.
- The Safety Assurance Factors for EHR Resilience (SAFER) Guides measure (Updated for 2024: a "no" will no longer satisfy this measure in 2024).
Am I Required to Report Promoting Interoperability Data?
There's one clinician type and several special status designations that result in automatic reweighting. These clinicians, groups, and APM Entities are exempt from reporting Promoting Interoperability data for the 2024 performance year:
- Clinician type: clinical social workers
- Special status: ambulatory surgical center (ASC)-based, hospital-based, non-patient facing, and small practice (Note: small practice is the only special status available to APM Entities.)
Beginning with the 2024 performance year, the following clinician types will no longer be automatically reweighted and are therefore required to report Promoting Interoperability data:
- Physical therapists
- Occupational therapists
- Qualified speech-language pathologists
- Qualified audiologists
- Clinical psychologists
- Registered dieticians or nutrition professionals
Individuals and groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception application, citing one of the following reasons for review and approval:
- MIPS eligible clinician using (decertified under the ONC Health IT Certification Program)
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
If your hardship exception is approved, the Promoting Interoperability performance category will receive a weight of 0% when calculating your final score and the 30% will be redistributed to another performance category (or categories) unless you submit data for the Promoting Interoperability performance category.
Learn more about how to apply for a Promoting Interoperability Hardship Exception.
How Should I Submit Data?
There are 3 submission types you can use for your Promoting Interoperability performance category data, depending on which you are. The are:
- Sign in and
- Sign in and upload
- via (API)
Determine how to submit data based on your submitter type below.
Submitter Type | Sign In and Attest | Sign In and Upload | Direct Submission (API) |
---|---|---|---|
MIPS eligible clinician | |||
A representative of a practice or APM Entity | |||
Third party intermediary |
How Are Measures Scored?
For measures that require a numerator and denominator, we calculate the performance rate for each measure using the numerators and denominators you submitted, and then multiply the performance rate by the total points available for the measure or objective. For scored measures that require a "yes" or "no", we award full points for measures submitted with a "yes".
For the Public Health and Clinical Data Exchange objective, you’ll be awarded full points if a “yes” is submitted for the 2 required measures (Immunization Registry Reporting and Electronic Case Reporting) or one “yes” and one exclusion. You’re also required to submit your level of active engagement for these 2 measures.
You must report all required measures (submit a “yes”/report at least one patient in the numerator, as applicable, or claim an applicable exclusion) or you’ll earn a zero for the Promoting Interoperability performance category.
If exclusions are claimed, the points for those measures will be reallocated to other measures.
What If We’re Reporting the APP as an APM Entity?
If you’re reporting as an APM Entity and the Entity includes MIPS eligible clinicians, the MIPS eligible clinicians will need to report Promoting Interoperability data, or this performance category will contribute zero points toward their final MIPS score.
APM Entities can choose to submit their Promoting Interoperability data at the APM Entity level. APM Entities also have the option to report Promoting Interoperability data at the individual or group level; individual and group data will be aggregated and averaged into a single score for the APM Entity.
Bonus Points
You can earn 5 for submitting a “yes” response for one of the optional Public Health and Clinical Data Exchange measures (Public Health Registry Reporting, Clinical Data Registry Reporting, or Syndromic Surveillance Reporting).