Promoting Interoperability Hardship Application
With the emphasis on flexibility and ease of data exchange, the Centers for Medicare and Medicaid Services (CMS) renamed the Advancing Care Information (ACI) to Promoting Interoperability (PI). WHN practices have raised concerns over challenges in reporting this category. The score of each practice affects the score for the ACO. A low score or failure to submit will lower the overall score for WHN and all participants.

WHN wrote to selected WHN participants regarding the submission of a hardship application on their behalf to CMS (a new option for 2018), excluding them from the PI category reporting requirement.

Practices excluded from the PI category reporting will be treated as “exempt” and will not be penalized for not reporting the PI category. The reporting exclusion will not negatively impact practices.
Interoperability Hardship Application

Qualifying Criteria

  • MIPS-eligible clinicians in small practices
  • MIPS-eligible clinicians using decertified EHR technology
  • Insufficient Internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT
In order to qualify, a practice was required to meet at least one of the above criteria.