2021 Program Requirements
In the Fiscal Year (FY) 2021 Medicare Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-term Care Hospital (LTCH) Prospective Payment System Final Rule, CMS finalized changes to the Medicare Promoting Interoperability Program for eligible hospitals, critical access hospitals (CAHs), and dual-eligible hospitals attesting to CMS.
The final rule adopted policies that will continue the advancement of certified electronic health record technology (CEHRT) utilization, further reduce burden, and increase interoperability and patient access to their health information.
Electronic Health Record (EHR) Reporting Period in 2021
The EHR reporting period for new and returning participants attesting to CMS is a minimum of any continuous, self-selected, 90-day period. Eligible hospitals and CAHs must successfully attest to avoid a downward Medicare payment adjustment.
2015 Edition CEHRT
Participants in the Medicare Promoting Interoperability Program will be required to use 2015 Edition CEHRT. For new participants, the 2015 Edition CEHRT does not have to be implemented on January 1, 2021. 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.
Objectives and Measures
Eligible hospitals, CAHs, and dual-eligible hospitals attesting to CMS will be required to report on four objectives.
- Electronic Prescribing
- Health Information Exchange
- Provider to Patient Exchange
- Public Health and Clinical Data Exchange
Listed below are measure changes that were finalized in the FY 2021 IPPS and LTCH final rule:
- The Query of Prescription Drug Monitoring Program (PDMP) Measure will remain optional and worth 5 bonus points. The measure will continue to require a Yes/No attestation.
- The Support Electronic Referral Loops by Receiving and Incorporating Health Information Measure, included in the Health Information Exchange objective, has been renamed to Support Electronic Referral Loops by Receiving and Reconciling Health Information.
CMS will continue to implement a performance-based scoring methodology. Eligible hospitals and CAHs are required to report certain measures from each of the four objectives, with performance-based scoring occurring at the individual measure-level. Each measure will contribute to the eligible hospital or CAHs total Medicare Promoting Interoperability Program score. A minimum of 50 points is required to satisfy the scoring requirement.
Electronic Clinical Quality Measures (eCQM) Requirements
For 2021, participants will be required to report two self-selected calendar quarters of eCQM data on four self-selected eCQMs.
More information can be found on the eCQMs Basics page.
Eligible hospitals and CAHs may submit a Medicare Promoting Interoperability Hardship Exception Application citing one of the following specified reasons for review and approval:
- Using decertified EHR technology
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
An approved hardship exception application will enable an eligible hospital or CAH to avoid a downward payment adjustment.
More information about payment adjustments and hardship exceptions can be found here.
Resources Now Available
- 2021 CEHRT Requirements Fact Sheet (PDF)
- 2021 Scoring Methodology Fact Sheet (PDF)
- 2021 eCQM Reporting Requirements (PDF)
- Security Risk Analysis Fact Sheet (PDF)
- Medicare Promoting Interoperability Program vs. Merit-based Incentive Payment System Promoting Interoperability Performance Category Infographic (PDF)
- 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 email@example.com or 1-866-288-8912.