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Policy Primer

2022 Hospital PI and eCQM Requirements

20 Minute Read

On Aug. 13, 2021, the Centers for Medicare & Medicaid Services (CMS) published the 2022 Inpatient Prospective Payment System (IPPS) final rule that includes updates to annual hospital payment rates and inpatient pay-for-performance programs. The 2022 IPPS final rule also updates policies for the Medicare hospital Promoting Interoperability (PI) and Inpatient Quality Reporting (IQR) programs, including electronic clinical quality measure (eCQM) reporting requirements.


What is Promoting Interoperability?

Hospitals must demonstrate meaningful use of their EHR to avoid Medicare penalties. There are three key tenets of the Promoting Interoperability (PI) program:

  • Use certified EHR technology (CEHRT)
  • Report PI measures
  • Submit electronic clinical quality measures (eCQMs)

Key policies at a glance

The hospital PI final rule prioritized several important CMS policy goals to promote the exchange of public health data and continue alignment across reporting programs. Of the three tenets of PI outlined in the table below, the biggest changes for 2022 impact PI measures.

Five highlights in the final rule
  • 1 Raises the bar for “meaningful use” of CEHRT
  • 2 Builds awareness of EHR safety risks
  • 3 A bigger, and required, focus on public health
  • 4 Optional measures offer flexibility to boost PI score
  • 5 Changes eCQM options in 2023 and 2024

What you should do in response

Use this checklist to guide your strategy for meeting 2022 requirements and get ready for future PI program changes.

1 Evaluate capability to meet updated PI requirements

  • Build awareness of SAFER Guides self-assessments across stakeholders and determine whether to report “Yes” or “No.”
  • Work with your state PHA and EHR vendor to report the four required public health measures.
  • Assess performance trends against the new 60-point threshold.

2 Explore optional measures to boost your PI score

  • Consider the optional HIE bi-directional exchange measure, worth 40 points, as an alternative to the reporting the two existing percentage-based HIE measures.
  • Prioritize the optional Query of PDMP measure to earn 10 bonus points.
  • Look into reporting one of the optional Public Health measures to earn 5 bonus points.

3 Prepare for forthcoming program changes 

  • Provide feedback on the data availability policy. CMS did not finalize proposed updates for increased data availability under the Patient Electronic Access measure, but the agency mentioned it welcomes feedback as it considers those updates for future rulemaking.
  • Plan for technology updates. Hospitals must implement 2015 Edition Cures Update CEHRT for the 2023 PI reporting period and keep up with changes to the available eCQM options.
  • Sustain PI performance beyond 90 days. The EHR reporting period will increase to a minimum continuous 180 days starting 2024.

What this means for the program

In raising the bar on meaningful EHR use, the PI program continues to play a key role in supporting federal strategic priorities—especially given the ongoing public health emergency. Many of the updates to 2022 hospital PI measures aim to bolster data exchange, with CMS focusing on two key goals: strengthening the United States’ public health reporting infrastructure and supporting care coordination between providers.

Hospitals should pay close attention to optional measures, such as Query of PDMP, as they offer a glimpse into long term program priorities. If history is any indicator, optional measures are likely to become required in future years.

It’s important to remember that meaningful EHR use is not a static concept. The pace of change will ebb and flow, as the PI program is a powerful tool that CMS can use to push the industry forward as new opportunities and challenges arise.

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