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2019 Program Requirements Medicare

Beginning in 2019, all eligible professionals (EPs), eligible hospitals, dual-eligible hospitals, and critical access hospitals (CAHs) are required to use 2015 edition certified electronic health record technology (CEHRT) to meet the requirements of the Promoting Interoperability Program. Note that the requirements for eligible hospitals, dual-eligible hospitals, and CAHs that submit an attestation to CMS under the Medicare Promoting Interoperability Program were updated in the 2019 IPPS final rule.  

In 2019, all Medicaid eligible hospitals and EPs must adhere to the requirements of their state’s Medicaid Promoting Interoperability Program and attest directly to their state. Visit the 2019 Promoting Interoperability Medicaid page for more information.

In the Fiscal Year (FY) 2019 Medicare Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-term Care Hospital (LTCH) Prospective Payment System Final Rule, CMS made changes to the Promoting Interoperability Programs for Medicare eligible hospitals, CAHs, and dual-eligible hospitals attesting to CMS.

The final rule adopted policies to continue the advancement of CEHRT utilization, reduce burden, and increase interoperability and patient access to their health information. Eligible hospitals and CAHs must successfully attest to avoid a negative Medicare payment adjustment.

EHR Reporting Period in 2019

For 2019, the EHR reporting period for new and returning participants attesting to CMS is a minimum of any continuous 90-day period. Visit the landing page for up-to-date information on the attestation deadline.

2015 Edition Certified EHR Technology

Beginning with the EHR reporting period in calendar year 2019, participants in the Medicare Promoting Interoperability Program are required to use 2015 Edition CEHRT. This requirement will be beneficial to health IT developers and health care providers to move to more up-to-date standards and functions that better support interoperable exchange of health information and improve clinical workflows. The 2015 Edition CEHRT did not have to be implemented on January 1, 2019. However, the functionality must be in place by the first day of the EHR reporting period. The eligible hospital or CAH must be using the 2015 Edition functionality for the full EHR reporting period. In many situations the product may be deployed, but pending certification.

Objectives and Measures 

In 2019, eligible hospitals, CAHs, and dual-eligible hospitals attesting to CMS will be required to report on four objectives. The 2019 Medicare specification sheets are available here.

Scoring Methodology 

In the FY 2019 IPPS LTCH final rule, CMS finalized changes to the scoring methodology to shift to a performance-based scoring methodology with fewer measures, instead of the previous threshold-based methodology. CMS believes this methodology will encourage hospitals to push themselves on measures that are most applicable to how care is delivered to patients, instead of increasing thresholds on measures that may not be as applicable to an individual hospital.

More information on the updated scoring methodology can be found below.

Extreme and Uncontrollable Circumstances

If your EHR vendor is unable to offer 2015 Edition CEHRT for the 2019 EHR reporting period, you can apply for a hardship exception to avoid a payment adjustment. 

In order to be approved for this hardship exception, eligible hospitals and CAH(s) must attest to facing Extreme and Uncontrollable Circumstances that prevented them from demonstrating meaningful use. More information and hardship exception applications for the 2019 reporting year can be found here.

Additional Information for Clinicians

Beginning in 2018, all eligible clinicians previously participating in the Medicare Promoting Interoperability Program are now required to report on Quality Payment Program (QPP) requirements. For more information on the Quality Payment Program, visit this website.

Resources Now Available

Contact Information

  • Medicare EPs may contact the Quality Payment Program help desk for assistance at or 1-866-288-8292.
  • Medicaid EPs and hospitals participating in the Medicaid Promoting Interoperability Program with inquiries about their participation should contact their State Medicaid Agencies.
  • Medicare and dually eligible hospitals participating in the Medicare and Medicaid Promoting Interoperability Programs may contact the QualityNet help desk for assistance at or 1-866-288-8912.