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Hospital Services
Medicare Promoting Interoperability Requirements for Eligible Hospitals and Critical Access Hospitals

CMS finalized changes to the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals (CAHs) 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 2022
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.

For calendar year (CY) 2022, in order to be considered a meaningful user and avoid a downward payment adjustment, eligible hospitals and CAHs may use (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures 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).

For CY 2022, the CEHRT functionality must be in place by the first day of the EHR reporting period and the product must be certified by the last day of the EHR reporting period. The eligible hospital or CAH must be using their selected version’s functionality for the full EHR reporting period.

Objectives and Measures
Eligible hospitals and CAHs attesting to CMS will be required to report on four scored objectives.

• Electronic Prescribing
• Health Information Exchange
• Provider to Patient Exchange
• Public Health and Clinical Data Exchange

Medicare Promoting Interoperability Program participants must also attest to the following:

• Security Risk Analysis measure
• Safety Assurance Factors for EHR Resilience (SAFER) Guides measure
• Actions to limit or restrict the compatibility or interoperability of CEHRT attestation
• Office of the National Coordinator for Health Information Technology (ONC) Direct Review Attestation Changes to measures for 2022 include:
• Adoption of the Health Information Exchange Bi-Directional Exchange measure as an alternative to the two existing measures (worth 40 points) under the Health Information Exchange Objective;
• Requiring reporting on four of the Public Health and Clinical Data Exchange Objective measures (worth 10 points):
• Syndromic Surveillance Reporting
• Immunization Registry Reporting
• Electronic Case Reporting; and
• Electronic Reportable Laboratory Result Reporting.
• Note: The Public Health Registry Reporting and Clinical Data Registry Reporting measures will remain optional and available for a total of 5 bonus points.

Scoring Methodology
CMS continues 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 60 points is now required to satisfy the scoring requirement and successfully attest. Additionally, the available bonus points for the Electronic Prescribing Objective’s Query of Prescription Drug Monitoring Program measure is now 10 points.

Electronic Clinical Quality Measures (eCQM) Requirements
Participants are required to report on three (out of nine) self-selected eCQMs and the Safe Use of Opioids – Concurrent Prescribing measure using three self-selected quarters of data.