Claimocity Claims
Promoting Interoperability:
Reporting & Scoring Explained
Miss a required PI element, and you can lose a quarter of your MIPS score in one step. That translates to real dollars for your Medicare reimbursements. It’s also a common contributing factor for practices that are assessed the maximum 9% payment penalty.
EHR systems don’t make reporting easy, and you’re already stretched thin managing patient care and documentation. Plus, CMS keeps trimming PI. For the 2026 data you submit in early 2027, two ONC attestations are gone. Starting with the 2027 performance year, the Security Risk Analysis measure is gone too.
This guide simplifies PI reporting for inpatient providers. We’ll explain what the category measures, how scoring actually works, and how to meet requirements without adding hours to your workload. You’ll walk away knowing exactly what’s expected and how to handle it efficiently. If you’re still learning the basics, check out our full guide to MIPS reporting.
What Is Promoting Interoperability?
Promoting Interoperability is a MIPS performance category that measures whether you’re actually using your EHR technology effectively. PI grew out of the old Medicare EHR Incentive Program, better known as Meaningful Use, and the concept remains the same: Prove your expensive EHR system improves patient care, not just your administrative burden. It focuses on whether key digital workflows are in place, such as e-prescribing, health information exchange, and patient access to records.
PI focuses on specific actions. Are you e-prescribing? Exchanging patient information with other providers electronically? Giving patients online access to their health records? These aren’t optional features anymore. They’re measurable requirements that directly affect your reimbursement.
This category accounts for 25% of your total MIPS score, making it more important than Improvement Activities and nearly as important as Quality and Cost.
How Promoting Interoperability Is Structured
Promoting Interoperability is built around a defined set of objectives that focus on how providers use certified EHR technology in day-to-day practice. Each reporting year, providers attest to specific measures tied to these objectives and receive a score based on performance.
- e-Prescribing to support safer, more efficient medication management, including querying your state’s prescription drug monitoring program
- Health Information Exchange to enable secure data sharing between providers
- Provider to Patient Exchange to give patients timely access to their health information
- Public Health and Clinical Data Exchange to support broader reporting and surveillance efforts
- Protect Patient Health Information from unauthorized access through the required SAFER Guides attestation (mandatory, not score-based). The Security Risk Analysis measure applies through 2026 data and is removed starting in 2027.
Not every provider reports every measure, while multiple attestations are frequently required for some of these focus areas. Requirements vary based on provider type, practice setting, and eligibility under CMS programs. Some inpatient clinicians aren’t required to submit PI at all. Understanding which objectives apply to you is the first step toward accurate reporting and scoring.
Why PI Still Matters for Inpatient Providers
Many hospitalists have PI reweighted automatically because they qualify as hospital-based. You can quickly confirm your status by checking the QPP Participation Status Tool.
That said, don’t take it for granted just because you call yourself a hospitalist. Mixed-setting groups, clinicians who split time with a clinic, and groups that lose hospital-based status when their mix of clinicians changes are subject to these PI requirements. If you want to learn more and prepare ahead of time, check out our dedicated guide to MIPS Eligibility and Reporting Requirements.
Understanding why PI matters beyond checking a compliance box helps you prioritize it appropriately. The stakes are higher than most providers realize, affecting everything from your revenue to your daily workflow efficiency.
Financial Impact: Get PI reporting right, and you protect your revenue. Get it wrong, and a zero in PI takes 25 points off your final score, which can be the difference between a positive adjustment and a penalty of up to 9%. That penalty comes off a lower base in 2027, when Medicare’s physician conversion factor drops 2.31%.
Operational Efficiency: When implemented correctly, PI measures streamline your existing workflows rather than complicating them. Electronic prescribing reduces phone calls to pharmacies. Health information exchange eliminates faxed records. Patient portal access cuts down on administrative calls about test results.
Better Care Coordination: PI requirements exist because they improve patient outcomes. Sharing information electronically with specialists, facilities, and primary care providers means fewer duplicated tests, better medication reconciliation, and smoother transitions of care for the patients you treat.
Understanding these requirements is the first step. The second is knowing exactly what you’re required to report and how the scoring actually works.
Promoting Interoperability Reporting Requirements: What You Need to Know
PI reporting involves multiple moving parts. Reporting obligations vary by provider type, performance must be captured during a defined reporting period, and missing a required element can significantly impact scoring.
Who Must Report PI
Some inpatient providers are required to report PI, but many clinicians qualify for automatic reweighting through one of these special statuses. CMS assigns them from your claims, so there’s nothing to apply for:
- Hospital-based: You furnish 75% or more of your covered professional services in inpatient, on-campus outpatient, off-campus outpatient, or emergency department settings. Groups qualify when more than 75% of their clinicians are hospital-based.
- Small practice: 15 or fewer clinicians.
- Non-patient facing: 100 or fewer patient-facing encounters.
- ASC-based: You furnish 75% or more of your covered professional services in an ambulatory surgical center.
Some practices may also meet criteria that exempt them from MIPS reporting altogether.
Determining whether PI applies to your organization should happen early in the reporting year. If you qualify for reweighting, CMS redistributes the PI percentage to your other performance categories. That keeps PI from counting against you, but it means you won’t earn points from PI performance either.
For this reason, some providers choose to report PI even when they’re not required to. If you submit PI data, CMS scores it and counts it toward your final score. If your PI performance is strong and you’re less confident in your Quality measures, this optional reporting can lift your final score and protect your payment adjustment. It’s one more option you have with a strong RCM software and services partner.
Hardship Exceptions
If you don’t have an automatic status but can’t meet PI requirements, you can apply for a reweighting exception. Qualifying reasons include:
- your certified EHR technology was decertified
- insufficient internet connectivity
- extreme and uncontrollable circumstances, such as a natural disaster or a major system outage
- lack of control over the availability of certified EHR technology
Each exception category has specific eligibility criteria, and applying for a hardship exception requires documentation. CMS sets an application deadline each year, so check QPP for the current date. Requesting a PI exception should be a deliberate decision, not a fallback for missed reporting or incomplete data. If you don’t qualify for reweighting and don’t report, the PI category scores as zero, and that’s 25% of your final score.
For the most up-to-date information on PI hardship exceptions and application deadlines, visit the Quality Payment Program website. Claimocity can help you determine whether your practice qualifies and guide you through the application process.
Everyone else reports PI. For hospitalists, that usually means groups where too few clinicians are hospital-based to qualify the group, or clinicians who split significant time between the hospital and a clinic. Groups that want facility-based scoring also must submit data in Improvement Activities or Promoting Interoperability.
Reporting Period
For 2027, MIPS PI data must be collected for a minimum of 180 continuous days during the calendar year. You can report for a longer period, including the full calendar year, but the days have to be consecutive. You can’t combine separate stretches.
Many providers do report for the full calendar year. It gives you more data points, reduces performance measure risk, and eliminates tracking a specific window. The performance year runs January 1 through December 31.
Data Submission
PI reporting happens through attestation. You confirm you met the requirements and provide supporting numbers. For required attestations, that’s a yes/no answer. For performance measures, you report your numerator and denominator data.
You can submit directly through the CMS Quality Payment Program portal or use a qualified registry like Patient360. Direct submission is allowed but may involve manual data entry. A registry reduces manual entry by taking data exported from your systems. You submit PI data at the same time as the rest of your MIPS data. The submission window opens in early January and typically closes March 31 of the following year. Missing the deadline means a zero for the entire PI category and payment penalties, unless your PI category is reweighted.
How PI Scoring Works
The MIPS Promoting Interoperability (PI) performance category is scored on a 100-point scale. Your PI score is calculated based on your performance across required measures, with additional points available for certain optional measures.
Required Measures: Each required measure is assigned a specific number of points. For measures based on numerator and denominator data, CMS calculates your performance rate and applies it to the points available for that measure. For yes/no measures, reporting "Yes" generally earns the available points.
Required Reporting Matters: You must report all required measures, or claim an applicable exclusion, to receive a PI performance category score. Failing to meet the reporting requirements can result in a score of zero. Required attestations, such as the SAFER Guides measure, don’t earn points, but answering "no" to any of them also results in a zero.
Bonus Points: Certain optional measures can provide additional points. However, your final PI score cannot exceed 100 points. For example, if your required measures add up to 85 points and you qualify for 5 additional bonus points, your PI score would be 90 points. If your calculated score exceeds 100, CMS caps it at 100 points.
What Score Should You Aim For?
You don’t need a perfect 100. There’s no separate PI threshold to clear. The 75-point benchmark applies to your overall MIPS score, and PI is worth 25% of it. A PI score of 80 adds 20 points to your final score, and a zero costs you all 25. If your overall score is less than 75, you’ll see a negative adjustment. If you score over 75, you’ll see a positive adjustment. Nevertheless, a good MIPS score is relative to the size and scope of your practice. It’s often best to focus on consistent reporting and meeting performance benchmarks rather than chasing a perfect score.
What's Changing in PI
The CY 2027 final rule trims several PI requirements:
- For 2026 data, submitted in early 2027: The ONC Direct Review attestation and the optional ONC-ACB Surveillance attestation are removed.
- For 2027: The Security Risk Analysis measure is removed, which takes away one of the attestations that can zero out the category. Electronic prior authorization becomes an optional measure worth 10 bonus points.
- For 2028: Electronic prior authorization becomes required, along with a new required attestation for electronic prior authorization of prescription drugs.
Hospital-based clinicians still have PI reweighted automatically. For every update, see what’s changing in MIPS for 2027.
Common Promoting Interoperability Challenges
Even experienced providers run into obstacles with PI reporting. Here are the most common issues:
Capturing EHR Data
Your system might have the right functions, but if workflows aren’t set up to capture data automatically, you might be scrambling at reporting time. Many providers discover too late that their EHR wasn’t tracking things correctly.
Monitoring Performance
PI measures require specific calculations. If you’re not monitoring these numbers regularly, you won’t know whether you’re meeting thresholds until it’s too late to course-correct.
Unclear Requirements and Exclusions
You may qualify for exclusions that aren’t always obvious. Reporting measures you could have excluded wastes time. Missing an exclusion can hurt your score if you didn’t meet the threshold.
Ignoring PI Throughout the Year
If you wait until January to get your reporting in order, you could discover missing data, configuration issues, and workflow gaps when there’s no time to fix them. It’s always better to be proactive rather than reactive.
The right tools and support eliminate most of these headaches. That’s why we conduct regular audits and deploy advanced medical billing software features for our clients. Along with proper EHR and facility integrations and expert guidance, PI reporting becomes routine rather than crisis management.
Best Practices for PI Reporting
Now that you know what to avoid, here’s what top-performing practices do differently:
Start Early
Don’t wait until the end of the year. Confirm whether PI applies to your organization and which measures you are required to report. Waiting until submission season increases the risk of missed requirements.
Build PI Into Daily Operations
PI measures should be part of your existing workflow, not separate tasks. Your EHR should automatically capture the correct data without extra steps for your staff. If your system isn’t configured to track this data, work with your EHR vendor to fix it early in the year.
Treat Required Measures and Attestations as Non-Negotiables
Required attestations are mandatory yes/no requirements. Failure to report a required measure or submit a required attestation, or claim an applicable exclusion, can result in a zero PI score for the entire category. Confirm each action is completed, documented, and supported by EHR data.
Monitor Throughout the Year
Review PI data during the reporting period, not just at year-end. Ongoing monitoring helps identify gaps while there is still time to correct them, particularly for measures tied to numerator and denominator thresholds.
Plan Submission Timelines
CMS deadlines are fixed, but internal timelines should be earlier. Build in time for data review and validation. Rushed submissions increase the risk of errors that cannot be corrected later.
Partner With MIPS Experts
PI regulations change frequently. Working with specialists who track those changes and understand reporting requirements eliminates confusion and reduces errors. The right approach will turn PI from a compliance burden into a routine part of practice management.
Simplify PI Reporting with Claimocity
Most providers dread PI season. Claimocity users don’t. We make PI reporting seamless by integrating directly with Patient360, a CMS-qualified registry. Your practice management system feeds data automatically to Patient360, which handles measure calculations, attestation requirements, and submission deadlines. You’re not manually pulling reports or entering data into the CMS portal any longer.
Here’s what changes when you partner with Claimocity: Your EHR workflows are configured to capture PI data from day one. Real-time dashboards show your performance throughout the year, so you can identify issues while there’s time to fix them. Custom workflows make sure required measures are completed and documented properly. Built-in compliance checks flag potential problems before submission.
We stay on top of CMS changes so you don’t have to. Our team gives your team expert support throughout the reporting year. We track regulatory changes, clarify which measures apply to your practice, and confirm your data is submission-ready. When CMS updates requirements or clarifies guidance, you’re not left figuring it out alone.
Providers using Claimocity’s MIPS integration spend less time on compliance and skip the year-end scramble. Consider the January panic over. Your PI data gets collected automatically, and submissions happen without missing information or last-minute discoveries.
Sources
- 42 CFR 414.1305: hospital-based, ASC-based, non-patient facing, small practice definitions
- 42 CFR 414.1320: 180-day PI performance period
- 42 CFR 414.1380: reweighting rules
- CY 2027 Physician Fee Schedule final rule, CMS-1848-F, 91 FR 70992 (November 9, 2026): ONC attestation removal, Security Risk Analysis removal, electronic prior authorization measures, conversion factor
