Medicare and Medicaid Promoting Interoperability Program Basics

Beginning in 2011, the Promoting Interoperability (formerly the Medicare and Medicaid EHR Incentive Programs) were developed to encourage eligible professionals (EPs) and eligible hospitals and critical access hospitals (CAHs) to adopt, implement, upgrade (AIU), and demonstrate meaningful use of certified electronic health record technology (CEHRT).

On September 2, 2020 CMS published the Fiscal Year (FY) 2021 Medicare Hospital Inpatient Prospective Payment System (IPPS) for Acute Care Hospitals and Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) Final Rule which included program requirements for calendar year (CY) 2021. In this final rule, CMS continued its advancement of CEHRT utilization, focusing on burden reduction, and improving interoperability and patient access to health information.

2021 Medicare Promoting Interoperability Program Requirements

  • A minimum EHR reporting period of any consecutive 90 days for new and returning participants.
  • Report on four objectives and their associated measures:
    • Electronic Prescribing
    • Health Information Exchange
    • Provider to Patient Exchange
    • Public Health and Clinical Data Exchange 
  • Eligible hospitals and CAHs may use (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cure Update criteria, or (3) a combination of the two in order to meet the CEHRT definition as finalized in the CY 2021 Physician Fee Schedule final rule (85 FR 84818 through 84828).
  • Report on four self-selected electronic clinical quality measures (eCQMs) from two self-selected quarters of CY 2021 data.
  • Submit a “Yes” to the following:
    • Security Risk Analysis measure
    • Prevention of Information Blocking attestations
    • ​​​​​​​ONC Direct Review attestation

2020 Medicaid Promoting Interoperability Program Requirements

  • All EPs, eligible hospitals and CAHs are required to use 2015 Edition CEHRT.
  • Meaningful Use Requirements for 2020
    • All EPs must report on a 90 day minimum EHR reporting period and meet the Stage 3 Meaningful Use requirements.
    • Stage 3 requirements can be found here.
  • eCQM Requirements for 2020
    • The list of eCQMs can be found here.
    • All returning EPs must report on a minimum 90 day eCQM reporting period..
    • EPs are required to report on any six eCQMs related to their scope of practice.
    • In addition, EPs are required to report on at least one outcome measure. If no outcome measures are relevant, EPs must report on at least one high-priority measure. If there are no outcome or high priority measures relevant to an EP’s scope of practice, they may report on any six relevant measures.
  • Program Year 2021 Policies
    • In 2021 all EPs will have 90-day EHR and eCQM reporting periods to allow states to meet the statutory deadline of December 31, 2021 for all incentives to be paid.

Additional Resources

Page Last Modified:
04/13/2021 09:44 AM