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Medicare and Medicaid Promoting Interoperability Program Basics

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.

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 CAHs to adopt, implement, upgrade (AIU), and demonstrate meaningful use of CEHRT.

On August 17, 2018 CMS published the Fiscal Year (FY) 2019 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 the requirements for 2019. In this final rule, CMS continued its overhaul of the Medicare Promoting Interoperability Program to continue the advancement of CEHRT utilization, focusing on burden reduction, and improving interoperability and patient access to health information.

On November 23, 2018 CMS published a final rule for the Medicare Physician Fee Schedule affecting Medicaid program requirements for 2019.

Changes for both the Medicare and Medicaid Programs for the 2019 program year are highlighted below:

2019 Medicare Promoting Interoperability Program Requirements

  • Beginning with the calendar year (CY) 2019 reporting period, all eligible hospitals and CAHs will be required to use 2015 Edition CEHRT.
  • Set a new performance-based scoring methodology for the Medicare Promoting Interoperability Program, that has a smaller set of objectives that will provide a more flexible, less-burdensome structure.
  • Finalized an EHR reporting period for new and returning participants attesting to CMS or their State Medicaid agency to a minimum of any continuous 90-day period within each CY.
  • For all eligible hospitals and CAHs who report electronically, the reporting period is one self-selected quarter of CY 2019 data reporting on at least four self-selected clinical quality measures (CQMs) from the set of 16.
  • The CQM submission period will be two months following the close of the CY CQM reporting period ending on February 29, 2020.
  • Added two optional measures in CY 2019: Query of Prescription Drug Monitoring Program (PDMP) and Verify Opioid Treatment Agreement.

2019 Medicaid Promoting Interoperability Program Requirements

  • Beginning with the CY 2019 reporting period, all EPs, eligible hospitals and CAHs will be required to use 2015 Edition CEHRT.
  • Meaningful Use Policies
    • The threshold for Stage 3 Objective 6, Measure 1 (View, Download, Transmit) and Measure 2 (Secure Messaging) was set at 5 percent for the remainder of the Medicaid Promoting Interoperability Program.
    • The requirement that only EPs in urgent care settings can use the Syndromic Surveillance measure to meet the Objective 8 (Public Health) was removed.
  • eCQM Policies for PY 2019
    • The list of available eCQMs for EPs in 2019 was aligned with the list of eCQMs available for Eligible Clinicians under MIPS in 2019. Those eCQMs can be found at
    • In 2019, returning EPs must report on a one-year eCQM reporting period and first-time meaningful users must report on a 90-day eCQM reporting period.
    • EPs are required to report on any six eCQMs related to their scope of practice.
    • In addition, Medicaid 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 reporting periods for MU and eCQM to allow states to meet the statutory deadline of December 31, 2021 for all incentives to be paid.

Additional Resources