Medicare QPP

Physicians Advocacy Institute

These resources have not been updated since 2023 but the general details remain relevant. For a summary of the key changes for CY 2024, please click here.

Frequently Asked Questions Updated for 2023

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2. What are the main differences from 2018’s Advancing Care Information (ACI) performance category, and 2022/2023’s PI performance category?

  • In 2019, CMS tabled the ACI performance category and replaced it with the PI performance category. Unlike the ACI category in 2018, the PI performance category does not require a base score measure. Instead, to earn points in the PI category clinicians must collect data for a minimum of any continuous 90-day period in the performance year, on 4 major objectives: 1) e-Prescribing, 2) Health Information Exchange, 3) Provider to Patient Exchange, and 4) Public Health and Clinical Data Exchange. Furthermore, the measures associated with these objectives must be reported through CEHRT of 2015 Edition functionality. A description of these objectives and the measures associated with them can be found in the table below:
    PI Objectives and Measures
    Objective Measure Required for PI Score? Max Points Reporting Requirement Exclusion
    (1) Protect Patient Health Information Security Risk Analysis Required 0 Yes/No Statement N/A
    Safety Assurance Factors for EHR Resilience (SAFER) Guides Required 0 Yes/No Statement N/A
    (2) Electronic Prescribing e-Prescribing Required 10 Numerator / Denominator Write fewer than 100 permissible prescriptions
    Query of Prescription
    Drug Monitoring
    Program (PDMP)
    Required 10 Yes/No Statement
    • Unable to electronically prescribe Schedule II opioids and Schedule III and IV drug in accordance with applicable law during the performance period
    • Write fewer than 100 permissible prescriptions
    • If querying a PDMP would impose an excessive worklfow or cost burden prior to the start of the performance period
    (3) Health Information Exchange Support Electronic Referral Loops by Sending Health Information Required 15 Numerator / Denominator Transfer or refer patients fewer than 100 times
    Support Electronic Referral Loops by Receiving and Reconciling Health Information Required 15 Numerator / Denominator
    • Receive fewer than 100 transitions of care or referrals, or has fewer than 100 encounters with patients never encountered during performance year
    Health Information Exchange Bi-Directional Exchange (required if submitted as an alternative to the two above) Required 30 Yes/No Statement N/A
    Enabling Exchange under Trusted Exchange Framework and Common Agreement (TEFCA) (required if submitted as an alternative to the two above) Required 30 Yes/No Statement N/A
    (4) Provider to Patient Exchange Provide Patients Electronic Access to their Health Information Required 25 Numerator / Denominator N/A
    (5) Public Health and Clinical Data Exchange Report to two different public health agencies or clinical data registries for any of the following:
    • Immunization Registry Reporting
    • Electronic Case Reporting
    Required 25 Yes/No
    Statement

    You will receive full points for submitting to 2 registries OR submitting to 1 registry and claiming 1
    Each of these measures has their own exclusion, but general exclusion criteria include:
    • Don't diagnose/treat any disease/condition associated with applicable registry/agency in their jurisdiction
    • Operate in a jurisdiction in which no agency/registry can accept
  • There are 10 total measures associated with the 4 objectives previously named (aside from the mandatory Security Risk Analysis), which make up the PI performance score. In actuality, only certain measures must be reported to receive a PI score (one Public Health and Clinical Data Exchange measure is for bonus points). More information on measuring requirements can be found on PAI’s PI Category Overview.  
  • In certain circumstances you may claim an exclusion from measures under specific objectives. In this case, the scoring criteria will be reweighted, and the remaining measures you submit will have a larger impact on your overall PI performance score. See PAI's PI Category Overview for additional details.



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