2020 Program Requirements Medicare

In the Fiscal Year (FY) 2020 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 Programs 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. 

EHR Reporting Period in 2020 

The EHR reporting period for new and returning participants attesting to CMS is a minimum of any continuous 90-day period, for both 2020 and 2021. Actions in the numerator and denominator of measures must be performed within a self-selected 90-day period in calendar year (CY) 2020. Eligible hospitals and CAHs must successfully attest to avoid a downward Medicare payment adjustment. 

Visit the Promoting Interoperability Programs home page for up-to-date information on the attestation deadline. 

2015 Edition CEHRT

In 2020, 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, 2020. 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

For 2020, eligible hospitals, CAHs, and dual-eligible hospitals attesting to CMS will be required to report on four objectives.

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

Listed below are changes that will affect the Electronic Prescribing objective:

• Query of Prescription Drug Monitoring Program (PDMP) Measure
  • Will remain optional in 2020.
  • Will be worth 5 bonus points.
  • Will require a Yes/No attestation.
• Verify Opioid Treatment Agreement Measure
  • Will be removed beginning in 2020. 

The 2020 Medicare Hospital Promoting Interoperability Program specification sheets can be found here (PDF).

Scoring Methodology 

The 2020 scoring methodology remains consistent with the changes made in 2019. CMS finalized changes to the scoring methodology to shift to a performance-based scoring methodology with fewer measures, instead of the previous threshold-based methodology. 

More information on the scoring methodology can be found here (PDF). 

Electronic Clinical Quality Measures (eCQM) Requirements 

For 2020 eCQM requirements, CMS has reduced the number of eCQMs available from 16 to eight. Participants must report on four eCQMs. The reporting period has also been changed to a self-selected calendar quarter of 2019. 

More information can be found on the CQMs Basics page. 

Hardship Exceptions

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 and hardship exception applications for the 2020 reporting year can be found here.

Resources Now Available

• FY 2020 Medicare Promoting Interoperability Program Overview Fact Sheet (PDF)
• 2015 Edition CEHRT Fact Sheet (PDF)
• 2020 Medicare Promoting Interoperability Program Scoring Methodology (PDF)
• Security Risk Analysis Fact Sheet (PDF)
• Medicare Promoting Interoperability Program vs. Merit-based Incentive Payment System Promoting Interoperability Performance Category Infographic (PDF) 
• Medicare Promoting Interoperability Program CY 2020 Performance Year Scoring Infographic (PDF)

Contact Information

• 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 qnetsupport@hcqis.org or 1-866-288-8912.