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Apr 10

Promoting Interoperability: What YOU Need to Know

How much do you know about the Promoting Interoperability category?

The Promoting Interoperability category came to fruition in 2018 when it replaced the Advancing Care Information (ACI) category of the QPP program. This performance category drives its roots into promoting patient engagement and the successful exchange of electronic communication through the use of certified electronic health record technology (CEHRT). Now that you have a brief understanding of what this category accomplishes, let’s delve into the information that you need to know as you move through the 2019 reporting year.

Submission Data for Promoting Interoperability

In 2019 ALL practice’s submitting measures for this category need to utilize 2015 Edition CEHRT. The new requirement mandates all practices either update, upgrade, or change their software vendor in order to report.

Clinicians choosing or mandated to report submit a single set of objectives and measures for this category that align with their 2015 Edition CEHRT. This year there are updated measures from the previous year and new measures added to this performance category. They are organized under four objectives. Please note: these are no longer categorized as performance or base score measures.


Clinicians submitting measures for the promoting interoperability category submit collected data from measure sets for each of the four objective measures. If a clinician is excluded from an objective, they may submit measures for the other objectives. These must be submitted for a 90 day continuous span, or more, throughout the 2019 reporting year.

In addition to submitting measures, clinicians must:

  • Submit a “yes” to the Prevention of Information Blocking Attestation,
  • Submit a “yes” to the ONC Direct Review Attestation; and
  • Submit a “yes” for the security risk analysis measure

Hardship Exceptions

When it comes to the Promoting Interoperability category, there are several reasons a clinician may be exempt from participation. Hardship exceptions are granted through “Hardship Exception Application” citing one of the following reasons:

  • MIPS eligible clinician in a small practice
  • MIPS eligible clinician using decertified EHR technology
  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

If a clinician chooses to submit an application for a hardship exception, it must be approved by CMS. Note: Some clinician types, i.e. physical therapist or clinical psychologist, will receive “Special Status” and not have to report for this category without submitting an application for exemption.

Measure Scoring

Good news – CMS simplified the way this category gets scored for the 2019 reporting year. The following information includes data regarding scoring for the performance year…

  • Each measure will be scored by multiplying the performance rate (calculated from the numerator and denominator you submit) by the available points for the measure
  • The Public Health and Clinical Data Exchange measures will be awarded full points if a yes is submitted for 2 registries or one yes and one exclusion
    • Failure to submit a numerator of at least one for measures or claim an exclusion will result in a zero being earned for the Promoting Interoperability performance category (Information provided by CMS)

Submitting Data for 2019

There are various methods that clinicians can choose to submit their data for MIPS. The available submission methods are as follows:

  • Attestation
  • Provider’s EHR
  • Qualified registry
  • QCDR
  • CMS Web Interface for groups of 25 clinicians or more

When you choose the submission method that your practice will utilize in the performance year, be sure to know what benchmarks you must meet to submit through that method.

As you can see, the Promoting Interoperability category includes many facets that your practice will need to consider as you move throughout the year. Promoting Interoperability is a crucial piece of the QPP program, and your practice can find success in the program if the right process are in place.

Do you have questions about QPP reporting with MicroMD Systems? Visit us at or call us at 800-624-8823.

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