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.

CEHRT

For calendar year (CY) 2021, 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 2021, 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. In many situations the product may be deployed but pending certification.

ONC’s 21^st Century Cures Act Final Rule made several changes to the existing 2015 Edition Health IT Certification Criteria. The following changes constitute the 2015 Edition Cures Update:

• Introduced new technical certification criteria to advance interoperability and make it easier for patients to access their own electronic health information on their smartphones.
• Added new privacy and security certification criteria.
• Revised the standards referenced by several existing 2015 Edition certification criteria, including United States Core Data for Interoperability updates.
• Removed and time-limited several 2015 Edition certification criteria.

To learn more about the 2015 Edition Cures Update, please review ONC's 21st Century Cures Act final rule. To check whether a health IT product has been certified to the 2015 Edition Cures Update criteria, visit the Certified Health IT Product List.

Objectives and Measures

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 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.

Scoring Methodology

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.

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 about payment adjustments and hardship exceptions can be found here.

Resources Now Available

• 2021 Medicare Hospital Objectives and Measures Table of Contents (PDF)
• 2021 CEHRT Requirements Fact Sheet (PDF)
• 2021 Scoring Methodology Fact Sheet (PDF)
• 2021 eCQM Reporting Requirements (PDF)
• Security Risk Analysis Fact Sheet (PDF)
• 2021 Medicare Promoting Interoperability Program vs. Merit-based Incentive Payment System Promoting Interoperability Performance Category Infographic (PDF)
• Medicare Promoting Interoperability Program Requirements for 2021 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.