July 5, 2025: The MIPS Deadline You Can’t Afford to Miss for Promoting Interoperability
For MIPS-eligible physicians, the Promoting Interoperability (PI) performance category has become a cornerstone of CMS's quality-focused care initiative. What many practices may not realize is that the deadline to start your 180-day performance period for PI in the 2025 performance year is Saturday, July 5, 2025.
This is not just another date to circle on the calendar. It’s the final opportunity to begin capturing data that counts toward your score in this high-impact category. Missing it could result in a zero for the entire category, which would negatively impact your final MIPS score and potentially affect your Medicare reimbursement.
Let's break down what this deadline means, what you should be doing right now, and how you can optimize your performance in the Promoting Interoperability category before it's too late.
Understanding the Importance of the 180-Day PI Performance Period
The Promoting Interoperability category accounts for 25% of your total MIPS final score. This category emphasizes patient engagement and the use of certified electronic health record technology (CEHRT) to improve care coordination.
To be scored in this category, clinicians must report data for a minimum of 180 continuous days within the performance year. That means July 5 is the last day you can start and still complete a full 180-day stretch before December 31, 2025.
Failing to meet this deadline means you will receive zero points for the PI category unless you qualify for and are approved for a Promoting Interoperability Hardship Exception.
What Should You Be Doing Right Now?
With the clock ticking, MIPS-eligible physicians should take immediate steps to ensure their PI reporting is on track. Here's what you need to prioritize:
1. Verify Use of 2015 Edition Cures Update CEHRT
CMS requires the use of 2015 Edition Cures Update certified EHR technology for the PI category. Log in to the Certified Health IT Product List (CHPL) and ensure your vendor's certification is up to date.
Tip: Ask your EHR vendor for their certification ID and match it with the CHPL to avoid costly mistakes.
2. Ensure Proper User Access and Training
Even if your technology is certified, your team still needs to be trained on how to use it effectively. Create staff roles for key PI measures such as e-prescribing, health information exchange, and providing patients access to their health information.
Best Practice: Conduct a short staff refresher training in June and document attendance for audit readiness.
3. Perform a Baseline PI Audit
Before your 180-day period begins, pull a test report on the following:
E-prescribing rates
Health Information Exchange usage
Patient access to data
Secure messaging activity
This early snapshot can help identify gaps that may be difficult to close once your reporting period begins.
4. Activate Required PI Measures
There are required and optional measures in the PI category. Required measures include:
e-Prescribing
Provide Patients Electronic Access to Their Health Information
Support Electronic Referral Loops
Public Health and Clinical Data Exchange
Make sure you’ve activated these workflows within your EHR and can track compliance.
5. Check Your Security Risk Assessment (SRA)
Although the SRA doesn’t require a specific 180-day window, it must be completed within the calendar year and is mandatory for receiving any score in the PI category.
Schedule this now if it hasn’t been done yet for 2025.
How to Optimize Your Promoting Interoperability Score
It’s not just about meeting the requirements; it’s about excelling. Here are a few ways to push your PI score higher:
1. Use CEHRT to Its Full Capacity
Many practices underutilize their EHR systems. Review your system's capabilities to identify underutilized features that can support scoring measures, such as Secure Messaging and Clinical Data Exchange.
2. Track and Analyze Weekly Data
Don't wait until the end of the 180 days to check your progress. Schedule weekly reports and reviews of PI performance metrics to ensure ongoing improvement and optimization. Adjust workflows in real time based on data trends.
3. Submit to All Applicable Public Health Agencies
You're only required to submit to one public health agency, but submitting to two or more can earn you bonus points.
4. Lean on Quality Improvement Staff
If your practice has a QI or Compliance Officer, make this a team effort. Delegate tasks such as monitoring patient engagement, tracking denominator compliance, and documenting improvement activities.
5. Document Everything
If you're ever audited, CMS may request proof of how you met PI measures. Keep screenshots, workflows, staff training logs, and vendor communications organized in a PI audit file.
Tip: Use cloud-based folders with date-stamped documentation.
Common Pitfalls and How to Avoid Them
Waiting too long to start: If you begin your 180-day period after July 5, you’ll automatically receive a zero in the PI category.
Assuming your EHR is certified. Always verify CEHRT status yourself.
Incomplete documentation: A lack of proof can harm you during audits.
Neglecting the SRA: This one overlooked item can nullify your entire PI score.
July 5 Isn’t Just a Deadline. It’s a Line in the Sand
If your practice hasn't already begun planning, now is the time to do so. By initiating your Promoting Interoperability performance period no later than Saturday, July 5, you ensure that your practice remains compliant, your MIPS score remains competitive, and your future Medicare reimbursement remains intact.
Remember: CMS does not offer extensions for missing the start of the performance period.
Download the PDF: Promoting Interoperability 180-Day Readiness Checklist.
To support your efforts, we’ve developed a downloadable Promoting Interoperability Readiness Checklist for 2025. It includes:
Verification steps for CEHRT
Set up requirements for the required measures.
Documentation tips for audit readiness
Staff training assignments
Next Steps
The Promoting Interoperability category should be approached as both a regulatory obligation and a patient-centered opportunity. While the July 5 deadline may feel like just another date, it’s a turning point that determines your path for the rest of the MIPS reporting year.
Don’t wait.
Download your checklist today and review it with your clinical team.
Schedule a consultation with our team at Chirpy Bird to review your current PI strategy and refine your reporting approach.
Let us help you get your ducks in a row before the deadline turns into a missed opportunity. For more personalized support or to request a walkthrough of your Promoting Interoperability performance plan, visit us at ChirpyBirdinc.com
