Scoring, Payment Adjustment, and Hardship Information

Performance-based Scoring Methodology

If a health care provider is eligible to participate in the Medicare Promoting Interoperability Program, they must successfully demonstrate meaningful use of their certified electronic health record (CEHRT) each year to avoid a downward payment adjustment. In the Fiscal Year 2019 Inpatient Prospective Payment System final rule, the Centers for Medicare & Medicaid Services (CMS) finalized a new performance-based scoring methodology for eligible hospitals and critical access hospitals (CAHs) that submit an attestation to CMS under the Medicare Promoting Interoperability Program. 

Medicare Promoting Interoperability Program Score

Beginning in 2019, eligible hospitals and CAHs will be required to report certain measures from the Promoting Interoperability Program’s four objectives, with performance-based scoring occurring at the individual measure-level. Each measure is scored based on the eligible hospital or CAH’s performance for that measure, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require a yes/no attestation. 

The scores for each of the individual measures are added together to calculate the total Promoting Interoperability score of up to 100 possible points for each eligible hospital or CAH. A total score of 50 points or more will satisfy the requirement to report on the objectives and measures of meaningful use, which is one of the requirements for an eligible hospital or CAH to be considered a meaningful EHR user and avoid a downward payment adjustment. Eligible hospitals or CAHs scoring below 50 points will not be considered meaningful EHR users.

For more information on the Promoting Interoperability score and methodology please review this fact sheet (PDF).

Medicaid Promoting Interoperability Program

In the 2019 Physician Fee Schedule final rule (83 FR 41668), States are not required to adopt the new scoring methodology and measures. States have the option to adopt the new scoring methodology and measures for their Medicaid Promoting Interoperability Programs. Any State that wishes to exercise this option must submit a change to its State Medicaid HIT Plan for CMS approval. If a State chooses not to submit such a change, or if the change is not approved, the new scoring methodology and measures will not apply.

For more information on the Medicaid Promoting Interoperability Program, visit here.

Medicare Payment Adjustment Fact Sheets

  • Medicare CAH Payment Adjustment information can be found here (PDF).
  • Medicare Eligible Hospital Payment Adjustment and Hardship Exception information can be found here (PDF).
  • Medicare Payment Adjustments & Hardship Exceptions Table from 2017 through 2020 can be found here (PDF).

Medicare Reconsideration Information

If an eligible hospital or CAH receives notification that they are subject to a Medicare Promoting Interoperability payment adjustment and believes there is an error, they can apply for reconsideration during the applicable application period.

The deadline for CAHs to submit a reconsideration form based on their 2018 payment adjustment is March 2, 2020. We will post the reconsideration form as soon as it is available.

Medicare Hardship Exception Information

Eligible hospitals and CAHs may be exempted from the Medicare downward payment adjustment if they can show that compliance with the requirement for being a meaningful EHR user would result in a significant hardship. To be considered for an exception (to avoid a downward payment adjustment), eligible hospitals and CAHs must complete and submit a Hardship Exception Application. If approved, the hardship exception is valid for only one payment adjustment year. Eligible hospitals and CAHs would need to submit a new application for subsequent years and in no case may an eligible hospital or CAH be granted an exception for more than 5 years.

Medicare Hardship Exception Application

  • The period for eligible hospitals and CAHs to submit hardship forms for the 2020  and 2018 payment adjustment years has ended.
  • More information on the Medicare Hardship Exception Application can be found here (PDF).
  • For questions regarding the Hardship Exception Application please contact the QualityNet help desk for assistance at or 1-866-288-8912.
Page Last Modified:
01/27/2020 04:15 PM