Calendar Year 2023 and 2024 Program Requirements

On August 28, 2023, CMS finalized changes to the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals (CAHs) for calendar year (CY) 2024.

This web page includes:

• An overview of the changes and program requirements for CY 2024.
• The CY 2023 requirements, to help participants report and attest by February 29, 2024.

For information on Hardship Exceptions and Payment Adjustments, please visit the Medicare Promoting Interoperability Program Resource Library.

EHR Reporting Period

The Electronic Health Record (EHR) reporting period for new and returning participants in CY 2024 will now be a minimum of any continuous, self-selected, 180-day period. 

For CY 2023, the EHR reporting period is a minimum of any continuous, self-selected, 90-day period.

Certified EHR Technology (CEHRT)

To be considered a meaningful user and avoid a downward payment adjustment, Medicare Promoting Interoperability Program participants are required to use CEHRT that has been updated to meet 2015 Edition Cures Update criteria.

The CY 2023 and 2024 CEHRT requirements for the Medicare Promoting Interoperability Program are as follows:

• 2015 Edition Cures Update functionality must be used as needed for a measure action to count in the numerator during the EHR reporting period chosen by the eligible hospital or CAH (a minimum of any continuous 90 days in 2023 and 180 days in 2024).
• In some situations, the product may be deployed during the EHR reporting period but pending certification. In such cases, the product must be updated to the 2015 Edition Cures Update criteria by the last day of the EHR reporting period.
• Eligible hospitals and CAHs must provide their EHR’s CMS Identification code from the Certified Health IT Product List (CHPL), available on HealthIT.gov, when submitting their data.

To learn more about the 2015 Edition Cures Update, please review ONC’s 21st Century Cures Act Final Rule and the ONC Certification Criteria webpage. 

To check whether a health IT product has been updated to the 2015 Edition Cures Update, visit the Certified Health IT Product List (CHPL) at https://chpl.healthit.gov/.

Objectives and Measures

Participants are required to report on four scored objectives and their measures.

1. Electronic Prescribing
2. Health Information Exchange
3. Provider to Patient Exchange
4. Public Health and Clinical Data Exchange

Participants are also required to report (yes/no) on the Protect Patient Health Information objective:

• Security Risk Analysis measure
• Safety Assurance Factors for EHR Resilience (SAFER) Guides measure
  • Beginning in CY 2024, participants will be required to attest “Yes” to having completed the SAFER Guides measure. Selecting “no” or not completing the requirement will result in automatic failure. 

There is also a required attestation: Actions to Limit or Restrict Interoperability of CEHRT Attestation.  The ONC direct review attestation is optional.

The objective and measure specification sheets for CY 2023 can be found here (ZIP).

The CY 2024 specification sheets will be available soon.

Scoring Methodology

CMS continues to implement a performance-based scoring methodology. Each measure will contribute to the eligible hospital or CAH’s total Medicare Promoting Interoperability Program score. A minimum of 60 points is required to satisfy the scoring requirement.

Electronic Clinical Quality Measures (eCQMs)

In CY 2023, participants must report on and submit a full year’s worth of data on the following:

• 3 self-selected eCQMs; AND
• The Safe Use of Opioids Concurrent Prescribing eCQM.

In CY 2024, participants must report on and submit a full year’s worth of data on the following:

• 3 self-selected eCQMs; 
• The Safe Use of Opioids – Concurrent Prescribing eCQM; and 
• The Severe Obstetric Complications eCQM; and the Cesarean Birth eCQM, for a total of six eCQMs Must submit a full year’s worth of data.