Upcoming Deadline for MIPS Promoting Interoperability Reporting

July 3, 2025

The deadline to begin your 180-day Promoting Interoperability (PI) performance period for 2025 MIPS is rapidly approaching. If you are planning to report PI and haven’t started your performance period yet, you must do so by July 5, 2025.

For steps to successfully report 2025 MIPS, review our blog: Are You on Track for 2025 MIPS Reporting Requirements?

Does My Practice Have to Report PI?

Small Practices (15 or fewer clinicians)

You can choose whether or not to report PI as you can claim an automatic PI hardship. But, if you report any PI data, you will be scored on the PI category.

Larger Practices (16+ clinicians)

You are required to report PI. However, if extenuating circumstances create an inability to perform the PI measures, you can apply for a PI hardship if. For more information, visit CMS’ hardship information page.

Reweighting and Category Impacts

Keep in mind that if you choose to take a hardship for PI, your other MIPS category weights will increase. With many Quality measures becoming topped out, it is becoming increasingly difficult to score well in Quality. We recommend reporting PI if you can.

If you are a small practice receiving an automatic hardship for PI, your Quality category will be reweighted to 40% of your overall MIPS score (assuming no hardships for other categories).
If you are a large practice receiving a hardship for PI, your Quality category will be reweighted to 55% of your overall MIPS score (assuming no hardships for other categories).

Important Information and Recommendations

If you report PI, you must perform the PI measures for 180 consecutive days. You must be using an EHR that meets the health IT certification criteria at 45 CFR 170.315, as required by the Assistant Secretary for Technology Policy (ASTP).

EHR Deadlines

You must have the functionality of the ASTP Base EHR definition by the first day of your Promoting Interoperability 180-day performance period in 2025.
- This includes the Decision support interventions (DSI) criteria which replaced the Clinical Decision Support (CDS) criteria on January 1, 2025.
Your EHR must be certified to the ASTP Base EHR definition by the last day of your Promoting Interoperability 180-day performance period in 2025.

Electronic Case Reporting (eCR) Requirements

Remember that if you were in Active Engagement Option 1 in 2024, you must progress to Option 2 in 2025. You have until the last day of your PI performance period to be in Option 2. For more information on the eCR measure, refer to our blog: Electronic Case Reporting in 2025.

If you are having trouble transitioning from Option 1 to Option 2,* you may be eligible to report an exclusion for this measure. For details, review our blog: Electronic Case Reporting: Clarification on Active Engagement Option 2 Deadline.

*In case you missed it, the CDC announced a temporary pause in eCR onboarding for new healthcare organizations.

Next Steps

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Written By: Sarrah Hakim, MHSA