Promoting Interoperability Score Reweighting Criteria (MIPS)

Under certain circumstances the Promoting Interoperability (PI) performance category of MIPS can be reweighted from 25% of the total MIPS score to 0%.   In this situation PI’s weighting shifts to the Quality performance category, giving Quality a weighting of 75% or in some cases 85% if the practice does not meet the minimum thresholds for scoring in the Cost category.

Simply not using Certified EHR Technology (CEHRT) does not qualify a clinician for this reweighting.   The reweighting to 0% means that the Advancing Care Information performance category isn’t included in the clinician’s or groups MIPS final score.

Reweighting Based on Clinician Type

The following types of clinicians are automatically reweighted to 0%:

  • Ambulatory Surgical Center (ASC) – based MIPS eligible clinicians (begins with the 2017 performance period)
  • Hospital-based MIPS eligible clinicians (in 2018 this also includes off-campus outpatient hospital service locations (Place of Service Code 19))
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Clinicians who lack face-to-face interactions with patients

These types of clinicians may elect to report PI measure data if they so choose. If they do they will be scored like any other clinician of group that is not eligible for reweighting.  It will represent 25% of your total MIPS score.  Since PI’s weighting would be shifted to Quality, some practices may wish to consider submitting PI data even if they are eligible for reweighting.   This would most likely depend on how well they are performing in the Quality category.

What are the Criteria for Clinicians or Groups to be Qualify as Hospital-based MIPS Eligible Clinicians? 

  • Reporting as an individual: the clinician must provide 75% or more of his/her covered professional services  (based on Place of Service Codes) in the:
    • Inpatient hospital setting
    • On-campus outpatient hospital setting
    • Off- campus outpatient hospital setting, or
    • Emergency room setting
  • Reporting as a group or Virtual Group: all of the MIPS eligible clinicians in the group must furnish 75% or more of their covered professional services (based on place of service codes) in the:
    • Inpatient hospital setting
    • On-campus outpatient hospital setting
    • Off-campus outpatient hospital setting
    • Emergency room setting

If any clinicians in the group do not provide 75% of more of their services in one of the above setting the whole group is disqualified from reweighting.  In 2018 all clinicians that have assigned their Medicare billing to the TIN must be included as members of the group.

Reweighting Based on Hardship Exemptions

Clinicians that face certain hardships may be eligible for reweighting. If they meet one of the requirements listed below they must submit a hardship application no later than December 31, 2018 for the 2018 performance year.

The following reasons may justify reweighting of your PI score to 0%:

  • Individual clinicians or small groups
  • Clinicians and groups that are using the EHR technology that has been decertified
  • Practices that have insufficient internet connectivity
  • The practice experiences extreme and uncontrollable circumstances
  • The clinician or group does not have control over the use of Certified EHR Technology