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MIPS 2021: All About the Promoting Interoperability Measures


MIPS (Merit-based Incentive Payment System) is a part of the Quality Payment Program (QPP), which came into effect in 2017. Its purpose was to move the Medicare part B providers to a performance-based payment system.

It replaced three pre-existing quality-reporting programs (PQRS, VBM, and MU) and made a single system with categories, based on which a score is determined called the MIPS composite or final score.


There are four categories in the MIPS program, which are

  1. Quality
  2. Improvements Activities (IA)
  3. Promoting Interoperability (PI)
  4. Cost

Each category makes up a certain percentage of the final score. And are responsible for determining how much of a positive payment adjustment a clinician will be receiving against the performance year. Moreover, the rules and regulations regarding each category change or get updated each year as well. It is the same case for MIPS 2021.

Today we will be focusing on the Promoting Interoperability (PI) category, its basics, and which requirements clinicians need to fulfill for successful MIPS 2021 reporting.

Promoting Interoperability (PI)

This category replaces the Medicare Electronic Health Records Incentive Program (EHR and Meaningful Use Program) and composes 25% of the final score.

It deals with patient engagement and the exchange of information through Certified Electronic Health Record Technology (CEHRT), in general.

Categories and Measures

There are 11 measures in this category, which are divided into four objectives or categories.

  1. Electronic Prescribing (e-prescribing)
  2. Provider to Patient Exchange
  3. Health Information Exchange
  4. Public Health and Clinical Data Exchange

Each of the chosen measures needs to be reported for 90 consecutive days, which can be done via a MIPS Qualified Registry.


This category consists of two measures.

It requires MIPS eligible clinicians to write at least one prescription and transmit it electronically through CEHRT.

This measure is worth 10 points.

  • Prescription Drug Monitoring Program (PDMP)

It is a bonus MIPS Quality Measure and does not need a mandatory attestation.

Moreover, it requires a MIPS eligible clinician to use data from CEHRT to examine PDMP for drug history regarding Schedule II opioids, following the applicable law.

There needs to be at least one Schedule II opioid prescribed electronically using CEHRT during the performance year to qualify for this.

It is worth 10 points. So, if you submit this measure with MIPS 2021 quality reporting data, you have a chance to gain high points in the MIPS PI category.

Provider to Patient Exchange

This category has one measure. In case you are not familiar with it, you can hire a third-party vendor, a MIPS Qualified Registry to submit their measures.

  • Provide Patients Access to their Healthcare Information

It requires the clinician to ensure that the patient or their representative has access to their health information. Including being able to transmit it, view it, and download it.

Any application or software can do this task. However, that tool is supposed to meet the Applications Programming Interface (API) specifications in the CEHRT.

It is worth 40 points in MIPS 2021 reporting.

Health Information Exchange

This category consists of three measures, which come as two options.

Option 1

  • Support Electronic Referral Loops by Submitting Health Information (Medical Records or Others) 

It requires the MIPS qualified clinicians to refer at least one of their patients to another healthcare provider. Including creating a summary of their care record using CEHRT and electronically exchanging it.

If submitted this MIPS quality measure, you can receive 20 points.

  • Support Electronic Referral Loops by Receiving & Reconciling Health Information

This requires the clinician to be the receiver of at least one electronic summary of a care record regarding patient encounters, including a transition of care record or a referral. Or it can be the acquisition and collection of information regarding a new patient, for reconciliation of information concerning medication, medical allergy, and current list of issues.

It is worth 20 points.

Option 2

  • Health Information Exchange (HIE) Bi-Directional Exchange

It requires MIPS-eligible clinicians for the bi-directional exchange of information with an HIE to support transitions of care and is worth 40 points.

You can choose to attest to either option as they both hold the same points. Moreover, it is up to you to go for MIPS 2021 reporting as an individual or via a MIPS Qualified Registry.

Public Health and Clinical Data Exchange

This MIPS quality category consists of five measures.

  • Immunization Reporting

It requires MIPS 2021 reporting clinicians to be in active engagement with a public health agency for the submission of immunization records and to receive immunization histories from the public health immunization registry or the immunization information system (IIS).

  • Syndromic Surveillance Reporting

For this measure, the MIPS eligible clinician needs to submit syndromic surveillance information with a public healthcare agency, preferably from an urgent care setting.

  • Electronic Case Reporting

It requires the clinician to actively engage with a healthcare agency to submit data regarding reportable cases.

  • Public Health Registry Reporting

For this, the clinician needs to be engaging with a public agency for information submitted to public health registries.

  • Clinical Data Registry Reporting

For this measure, the MIPS qualified clinician needs to actively be engaging with a clinical data registry for information submission.

You can choose any two measures out of the five listed here for reporting, and they will be worth 10 points in total.

Reporting and Submission Criteria

Clinicians can collect data for their respective measures and report it by using an Electronic Health Record (EHR) that meets the following criteria:

  1. Technology that meets the 2015 Edition certification criteria, or
  2. Technology that meets the 2015 Cures Update criteria, or
  3. A combination of both

You can ask your MIPS 2021 Qualified Registry in this regard.

Data collection for most measures from each objective takes place for a consecutive period of 90 days.

In addition to submitting the measures, clinicians also must provide their EHR’s CMS Identification Code. However, this code must come from the Certified Health IT Product List (CHPL) and then add a “yes” for each of the following:

  1. The Prevention of Information Blocking Attestation
  2. The ONC Direct Review Attestation
  3. The security risk analysis measure

The data for MIPS 2021 reporting regarding each measure can be submitted by:

  1. The clinicians
  2. a representative of a practice, a virtual group, or an APM Entity
  3. Third-party intermediaries as a Qualified Registry

Hardship Exceptions 

A clinician can apply for Promoting Interoperability Performance Category Hardship Exception in MIPS 2021 reporting. It allows them to not participate in activities from this category, which is permitted on the following grounds if you:

  1. Are MIPS eligible clinicians with a small practice
  2. Are a MIPS eligible clinician using a certified EHR Technology
  3. Have poor internet connectivity
  4. Are undergoing extreme and uncontrollable circumstances
  5. Lack of control over the availability of CEHRT

If your application is approved, then you will receive a 0% in the Promoting Interoperability category. Its 25% will get redistributed to another objective (or categories).

But, if you are a clinician with a special designation based on status (hospital-based) or type (physical therapist), you will not need to submit this application.

If you are a part of a group or a virtual group, all the clinicians included in the group will have to qualify for reweighing for the entire group to be reevaluated, unless they too have special status designations.


If you are a MIPS eligible clinician, this information will help you strategize better for the PI category. Assistance from a MIPS Qualified Registry will take all of your load to submit MIPS 2021 data timely to CMS.

You can learn more about the program here:

Medical billing services, Medical billing service companies, Medical billing services near me, Revenue cycle management

P3 Defines the Role of Medical Billers and Coders

Any person who thinks there is a difference between medical billers and medical coders is right.

Because there is a difference. With defined roles, they bring the right charisma to a physician’s revenue cycle. Nevertheless, one depends on the other for the completion of the billing process.

Medical billing services hire both professionals to carry out an effective revenue cycle management process on behalf of healthcare providers. Theoretically speaking, both professions require professionals to read, interpret, and comprehend Electronic Health Records (EHRs) and doctors’ notes. Hence, their education in science is a must.

We all know that medical billing is a complex process. But with medical coders and billers assigned to claims, medical billing becomes all the more manageable. Their capabilities provide all the help a healthcare provider needs to process medical billing claims.

For you, as a primary care physician or a specialty-specific clinician, an authentic team of health IT experts may, rightfully, carve the way to a successful practice.

Coding: Where Medical Billing Services Begin

Medical coding is a definitive structure of the medical bill. It becomes an integral part of medical billing service which reflects each and everything in a proper, organized, and coded form. At times such as this pandemic, the healthcare sky is lit with updates; new codes for COVID-19 have surfaced, so coders have a responsibility to stay in touch with CMS updates.

Moreover, they must remain proficient and knowledgeable in the ICD-10 coding system – the coding system that classifies diseases. The other one being the CPT set of codes identifies the treatment aspect of received cure.

The above systems help convert medical jargon into easier alphanumeric codes. For people inside and outside the medical industry, it may be hard to understand the names of diseases and certain procedures. Thus, the availability of these coding systems provides a comprehensive path to diseases and their solutions.

Since there are thousands of diseases, symptoms, and cures, it is not possible to write to them in complete form all the time. The only way possible is to design a coding system that classifies them.

Medical coders are required to manifest the knowledge of thousands of CPT and ICD-10 codes accordingly. Moreover, coders translate medical records for reimbursements later.

This gives us an overview of what coders are responsible for.

Medical Billing is the Social Part of Coding

After proofreading the claims, next comes the job of billing professionals to forward them to insurance companies.

A claim that is prepared by the coder has to go through a process; the person who carries it out through to the end is a medical biller. If it is a small practice, usually, there will be a small group of medical billers. However, to tend to a larger practice or hospital, there’s a whole team of billers and coders. Their times often concur with the time of the practice, but they can also work remotely to address claims as they come.

Without experienced billing personnel on your side, a health care facility, or a primary care physician’s revenue cycle would fail to function. Here, at P3, we have a whole team dedicated to medical billing outsourcing, so feel free to reach out at this number: 1-844-557-3227.


Billers to devise the billing claim use information emanating in the form of codes by medical coders. That claim becomes the first-hand information for insurance companies to release payments. A well-written billing claim without errors has a higher first-time acceptance rate. Furthermore, collections occur fast, almost within 2 weeks.

If patients have outstanding bills, the medical billing experts are required to contact them as part of the following-up process. They will walk them through the process and inform them about any deductibles, copayments, or other insurance liabilities.

Besides, medical billing and coding teams coordinate with insurance companies to get providers on board if they are not enlisted with them. Sometimes the patients visit providers who are out of network, and not on their health plan. Then, the medical billing services have an additional role to play, to enlist such providers with insurance companies. To speed up things, doctors must provide any documentation that is urgently required to complete the registration process.

Filing appeals and conversing with patients is part of their job. There is little time between denial and resubmission; therefore, we must act fast, recompile, proofread, and resubmit.

Where Do They Work?

‘Medical billing services near me’ is one of the search terms often searched on Google. Why?

Because, one, physicians are in search of someone nearby; second, if they can find them nearby, they are physically reachable. However, the remote nature of work has popularized the job amongst outsourcing companies. Therein, we hear the term, medical billing outsourcing.

Most billers and coders are present on LinkedIn with incredible job portfolios. Often you’ll find abbreviations such as CPC – Certified Professional Coder – besides their names. Also, you’ll find abbreviations such as CCA – Certified Coding Associate – and CCS – Certified Coding Specialist – with their names.


The prerequisites for this job are at least a high school diploma with a science background. However, an associate degree in medical billing helps convincingly in the long run.

You have four studying options:

  1. Bachelor’s degree in a health-related subject (4 years)
  2. Associate degree in medical billing & coding (2 years)
  3. Diploma (1 year)
  4. Certification (a couple of months)

All of these studying programs lead towards a bright future that is well-respected and well-paid.

Pro Tip – Choose schools that are recognized by AHIMA or AAPC.

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