Physicians Advocacy Institute

Frequently Asked Questions Updated for 2021


1. What are the exemptions for the PI category? What do they mean and how are they implemented?

  1. There are two avenues of exemption for the PI category. In the first option, you qualify for automatic reweighting if you are any of the following clinicians:
    1. Ambulatory Surgical center (ASC)-based MIPS eligible clinician
    2. Hospital-based MIPS eligible clinician
    3. Non-patient facing clinician
    4. Physician assistant
    5. Nurse practitioner
    6. Clinical nurse specialist
    7. Certified registered nurse anesthetist
    8. Physical therapist
    9. Occupational therapist
    10. Qualified speech-language pathologist
    11. Qualified audiologist
    12. Clinical psychologist
    13. Registered dietitian or nutrition professional
  2. In the second option, you may receive an exclusion if you qualify for a “significant hardship.” CMS has defined criteria for physicians and practices to apply for a “significant hardship” which would re-weight the promoting interoperability (PI) category to 0% of the 2021 MIPS final score for MIPS eligible clinicians. The 25% PI weight would be re-assigned to the quality performance category (for a total weight of 80% of the MIPS final score).

    The relevant significant hardships applicable to not having an EHR include:
    • Insufficient Internet Connectivity
    • Extreme and Uncontrollable Circumstances
    • Lack of Control over the Availability of CEHRT
    • MIPS eligible clinicians in small practices of 15 or fewer eligible clinicians
    • Decertified EHR

    For additional information please see the PI Category Hardship and Reweighting resource.

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