Calendar Year 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.

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. 

Certified EHR Technology (CEHRT)

The Medicare Promoting Interoperability Program and the MIPS Promoting Interoperability performance category updated the Base EHR definition to align with ONC’s regulations (HTI-1 final rule, 88 FR 23759)(CY 2024 PFS final rule, 88 FR 79307). 

ONC finalized their proposals to move away from a yearly “edition” construct for certification criteria; instead, all certification criteria will be “edition-less. 

All references to the “2015 Edition health IT certification criteria” have been replaced with “ONC health IT certification criteria”. 

Certification criteria will be maintained and updated at 45 CFR 170.315.

Future updates to the definition of Base EHR (45 CFR 170.102 and 170.315) will be incorporated into the CEHRT definition, without additional regulatory action by CMS.

To learn more about the ONC Health IT certification criteria, please review the ONC Certification Criteria webpage. 

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 2024 can be found here (ZIP).

The CY 2024 specification sheets can be found here (ZIP).

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)

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.