Requirements for Eligible Clinicians

The MIPS Promoting Interoperability category serves as the clinician-focused component of CMS’ digital health strategy, accounting for 25% of the overall MIPS score. This program affects individual eligible clinicians and groups participating in traditional Medicare, requiring them to demonstrate meaningful use of CEHRT in ambulatory settings. Unlike the hospital program, MIPS PI offers more flexibility through reweighting options and shorter reporting periods.

Program Framework

Eligible Clinicians Include:

Physicians (MD/DO)
Physician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered Nurse Anesthetists
Groups including these clinician types

Performance Period:

Minimum: Any continuous 90 days in 2025
Recommended: Full calendar year
Must use 2015 Edition CEHRT

2025 Objectives and Measures

Objective	Measures	Points	Required
e-Prescribing	e-Prescribing	10	Yes
Health Information Exchange	Support Electronic Referral Loops (Send)	15	Yes
Health Information Exchange	Support Electronic Referral Loops (Receive)	15	Yes
Provider to Patient Exchange	Provide Patients Electronic Access	40	Yes
Public Health	Report to 2 registries	20	Yes

Bonus Opportunities

Query of PDMP: Up to 10 bonus points
SAFER Guides completion: 5 bonus points
Maximum possible score: 110 points

Reweighting and Exceptions

Automatic Reweighting (No Application):

Small practices (≤15 clinicians)
Hospital-based clinicians
Non-patient facing clinicians
ASC-based clinicians
Certain specialties (radiology, pathology, etc.)

Hardship Exceptions (Application Required):

Decertified EHR
Insufficient internet connectivity
Extreme and uncontrollable circumstances
Lack of control over CEHRT

Scoring Impact

PI Score Calculation:
Points Earned / 100 = PI Performance Rate
PI Performance Rate × 25% = MIPS Contribution

Example:
85 points earned
85/100 = 85% PI rate
85% × 25% = 21.25% of final MIPS score

Key Differences from Hospital Program

Shorter minimum reporting period (90 vs 180 days)
Fewer public health requirements (2 vs 4)
Reweighting options available
Part of composite MIPS score
Different measure specifications

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