Meeting the Minimum PI Data Submission Requirements (A Tutorial)
Promoting Interoperability (PI) isn’t the biggest MIPS category by weight, but it’s often the one that causes the most confusion. At Chirpy Bird, we’ve helped dozens of practices prevent costly penalties simply by meeting the minimum PI submission requirements. It’s not about doing more. It’s about doing it right.
This tutorial walks you through a straightforward, step-by-step approach to meet the minimum PI requirements in 2025. Whether you’re a solo practitioner or managing a multi-specialty group, this guide will help you report accurately and avoid unnecessary risk.
Why Minimum PI Submission Matters
In 2025, Promoting Interoperability counts for 25% of your total MIPS final score—unless CMS has granted you a reweighting. That means missing even a single required measure can zero out your PI score and jeopardize your reimbursement.
Many providers mistakenly believe that meeting the minimum means doing the bare minimum. Not true. You must meet specific technical, operational, and attestation requirements to be counted.
Step 1: Confirm Your Eligibility and Exceptions
Not all MIPS providers are required to report on the Promoting Interoperability measure. Before you begin:
Verify if your practice is eligible for automatic reweighting.
Examples include: hospital-based clinicians, non-patient-facing clinicians, or small practices (if a hardship is requested).
If you qualify for a hardship, submit your exception request by Dec 31, 2025, at 8 p.m. ET.
Action Step: Log in to the QPP portal and verify your eligibility status.
Step 2: Use Certified EHR Technology (CEHRT)
This is non-negotiable. You must use CEHRT certified to the 2023 Edition Cures Update for the entire 180-day performance period.
If your vendor doesn’t meet the Cures Update standard, your data won’t count.
👉 Action Step: Request that your EHR vendor provide documentation of their 2023 Cures Update certification. Save this file for your audit file.
Step 3: Choose Your 180-Day Performance Period
CMS requires that you report for a minimum of 180 consecutive days in 2025. The latest you can start is July 5, 2025.
During this window, your EHR must:
Be fully functional
Be used consistently for data capture.
Allow you to fulfill all required measures.
👉 Action Step: Circle July 5 on your calendar. If you haven’t started reporting by that date, you risk falling short.
Step 4: Complete All Required Measures or Claim Valid Exclusions
There are six core activities in the Promoting Interoperability category. Some are scored, while others are attestation-only; however, all are required to receive a non-zero PI score.
1. e-Prescribing (10 points)
You must submit the number of prescriptions written electronically and those that were not.
Exclusion available if you write fewer than 100 permissible prescriptions during the period.
2. Health Information Exchange (HIE) (20 points)
This includes:
Sending electronic summaries of care for transitions and referrals
Receiving and incorporating summaries into your EHR
No exclusion is available unless you have fewer than 100 transitions of care.
3. Provider to Patient Exchange (25 points)
You must provide timely access to health information for more than 80% of unique patients seen during the reporting period.
Ensure patients can access their data through a portal or third-party app.
4. Public Health and Clinical Data Exchange (25 points)
Choose two types of public health registry reporting to earn full credit.
Examples:
Immunization registry reporting
Electronic case reporting
Syndromic surveillance
👉 Pro tip: If you’re connected to your local immunization registry and submitting data consistently, that’s one box checked.
5. Security Risk Analysis (Attestation Required)
Conduct a full security risk analysis of your CEHRT environment.
Must be completed within the calendar year.
Include physical, technical, and administrative safeguards.
6. SAFER Guides (Attestation Required)
You must attest that your practice reviewed the Safety Assurance Factors for EHR Resilience (SAFER) Guides.
These cover nine areas of EHR safety, including contingency planning and communication of test results.
👉 Action Step: Download and review the SAFER Guides at healthit.gov. Document the review in your internal compliance file.
Step 5: Track Performance in Real-Time
Minimum submission is not the same as last-minute submission. Use your EHR or a third-party MIPS dashboard to track:
Patient portal activations
Referral data exchanges
Prescription counts
Registry connection status
👉 Tip: Set a recurring check-in (monthly or quarterly) with your team to monitor progress and flag issues early.
Step 6: Build and Store Your Audit File
Every MIPS provider must keep documentation for at least six years in case of a CMS audit. For PI, your audit file should include:
CEHRT certification details
Screenshots of your EHR dashboard
Copies of the public health registry connection documentation
Notes from your Security Risk Analysis
Evidence of SAFER Guide review
Any hardship exception confirmations
👉 Bonus Tip: Name one team member as your MIPS document keeper. Consistency prevents a scramble.
Step 7: Submit Through the QPP Portal or Your Registry
You’ll submit your PI data between January 1, 2026, and March 31, 2026.
Data can be submitted through:
QPP portal
Third-party submission vendor
Qualified registry
👉 Action Step: Choose your method by Q4 and complete a dry run. Ensure your data maps correctly and meet measure thresholds.
Common Mistakes to Avoid
Late performance period start. If you begin after July 5, your data won’t be valid for the 180-day minimum.
Missing CEHRT certification. You must use certified software the entire time.
Skipping required attestations. Even if they’re “no points,” they’re still mandatory.
Forgetting exclusions. Claim them in the QPP portal during the submission process.
✅ Final Checklist: Minimum PI Data Submission Requirements
CEHRT certified to 2023 Cures Update
Chosen a 180-day continuous performance period (by July 5)
Completed required measures or claimed valid exclusions
Conducted a Security Risk Analysis
Reviewed the SAFER Guides
Created an audit file
Submitted data by March 31, 2026
Here’s the thing,
Meeting the minimum PI submission requirements isn’t just about checking boxes. It’s about protecting your score, your revenue, and your compliance profile.
Done well, Promoting Interoperability can be one of the easiest categories to succeed in. But skipped steps or assumptions can easily turn a safe bet into a red flag.
At Chirpy Bird, we walk our clients through every phase—from CEHRT validation to submission upload—so you never have to guess.
Ready for your 30-minute PI check-in?
Let us help you align your workflow, document your compliance, and avoid submission-day surprises.
Schedule a call with us today.
