Cheat Sheet

Hospital Promoting Interoperability (PI) program

10 Minute Read

Key Takeaways
  • The PI program encourages adoption and meaningful use of certified electronic health record technology (CEHRT).
  • CMS established three tenets that hospitals must meet to satisfy PI program requirements: using CEHRT, reporting PI measures, and reporting electronic clinical quality measures (eCQMs).
  • Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) must fulfill PI program requirements year-over-year in order to avoid hefty Medicare penalties.
 

What is it?

The Promoting Interoperability (PI) program is one way the federal government encourages providers to use electronic health records (EHRs). But it’s not enough to simply use EHRs, providers must demonstrate they are using EHRs meaningfully to exchange information with other providers and grant access to electronic health information for patients. Hospitals must use certified EHR technology (CEHRT) to collect and report PI measures to CMS.

Program history

Established in 2011, the PI program was previously called the EHR Incentive Programs, or Meaningful Use (MU). The program initially offered financial incentives to increase EHR adoption among providers. CMS implemented penalties for providers who failed to meet program requirements starting 2015.

The program has evolved to encourage more advanced use of EHR functionalities over the years. CMS overhauled the MU program in 2019, renaming it the PI program and restructuring its requirements under a performance-based scoring methodology.

Participants

Medicare Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) participate in the PI program each year. These hospitals must use certified EHR technology (CEHRT) to collect and report PI measures to CMS. The program also included Medicare Eligible Professionals (EPs) in previous years. But starting 2017, CMS sunset the standalone Medicare EP program and incorporated PI requirements into the Merit-based Incentive Payment System (MIPS) track under the Quality Payment Program.

 

Why does it matter?

Hospitals must satisfy PI program requirements year-over-year in order to avoid hefty penalties applied to Medicare reimbursement. For EHs, the annual IPPS1 market basket update is reduced by 75% percent. Whereas for CAHs, Medicare reimbursement is reduced from 101% to 100%. See our Medicare hospital PI penalty estimator to assess the potential financial impact for your hospital.

Beyond avoiding penalties, hospitals also see broader benefits from engaging in meaningful use of EHRs. Data sharing under the PI program can improve patient care in several ways:

  • Allow greater coordination across providers and care settings
  • Increase patient safety through access to more comprehensive data
  • Boost patient engagement in their care through greater access to data
  • Equip patients with data to make more informed health decisions
  • Support data-driven population health initiatives

The amount of electronic health information available today would not be possible without the PI program, which was responsible for driving significant increases in EHR adoption. CMS continues to leverage the PI program to advance health IT capabilities that support its policy goals for improving care quality and efficiency.

1. IPPS: Inpatient Prospective Payment System. Each year the IPPS final rule establishes the annual market basket update, a percentage update to Medicare hospital reimbursement that reflects inflation in costs of goods and services used by hospitals in treating Medicare patients. 

 

How does it work?

CMS establishes hospital PI requirements in the annual Inpatient Prospective Payment System (IPPS) rule. The PI program has three tenets—or components: adopt certified EHR technology (CEHRT); meet PI objectives and measures requirements; and report electronic clinical quality measures (eCQMs). Hospitals must satisfy all components of the PI program or face penalties.

Use CEHRT

Hospitals must use an EHR that has been certified to standards established by the Office of the National Coordinator for Health Information Technology (ONC). Starting 2019, CMS requires hospitals to use 2015 Edition CEHRT.

Meet objectives and measures

Hospitals must conduct an annual security risk analysis, and report PI measures across several objectives—electronic prescribing, health information exchange, provider to patient exchange, and public health and clinical data exchange. Points are awarded based on measure performance, and hospitals must earn at least 50 points to satisfy PI program requirements. Hospitals can select any minimum continuous 90-day period of PI data to report.

Report eCQMs

Hospitals satisfy the eCQM requirement by reporting data to CMS, and there are no performance thresholds to meet. For 2021, hospitals must report four eCQMs from two self-selected calendar quarters. CMS will increase the number of required calendar quarters each year until 2023, when hospitals must begin reporting all four calendar quarters.

 
Conversations you should be having
  1. Determine who is accountable for monitoring annual rulemaking to prepare for future PI program changes.

  2. Align your hospital PI strategy with broader health IT and quality reporting initiatives.

  3. Identify EHR workflow optimization opportunities to reduce reporting burden and improve PI performance if necessary.

Meeting PI program requirements requires ongoing involvement from stakeholders across multiple disciplines. Whenever hospitals make updates to their EHR configuration or workflow in response to PI program changes, it’s important to engage leadership from IT, quality, and clinical departments to address potential impact on performance and reporting.

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