2011–2017: Meaningful Use EHR Incentive Program (Early Years)
Before being renamed Promoting Interoperability, the program was known as the Medicare and Medicaid EHR Incentive Programs and focused on “Meaningful Use” of certified EHR technology (CEHRT). Objectives and reporting evolved in stages:
Stages of Meaningful Use:
- Stage 1 (2011–2012): Establish basic EHR data capture and patient access (e.g., electronic patient information and demographics).
- Stage 2 (2014 onward): Expanded requirements including secure messaging, advanced clinical processes, and structured data exchange.
- Stage 3 (2016 onward): Greater focus on improved outcomes, interoperability, and patient engagement.
Participants were required to:
- Adopt/implement/upgrade and demonstrate meaningful use of CEHRT.
- Report on specific objectives and measures, including clinical quality measures
(eCQMs), to receive incentive payments.
2018: Renaming to Promoting Interoperability
In April 2018, CMS renamed the EHR Incentive Programs to Promoting Interoperability Programs to highlight a shift from basic meaningful use to prioritizing interoperability, information exchange, and patient access to health data.
At this point:
- Eligible professionals reporting moved over to the MIPS Promoting Interoperability
performance category. - Eligible hospitals and CAHs continued reporting under a Medicare Promoting
Interoperability Program.
2020–2021: Tuning Requirements
Key rules incorporated:
- Minimum 90-day EHR reporting periods for hospitals and CAHs for Medicarereporting.
- 2015 Edition CEHRT became required for participants.
Medicaid Promoting Interoperability payments ended on December 31, 2021.
2022: Updated CEHRT & Scoring
For Calendar Year (CY) 2022 requirements under Medicare:
- 90-day EHR reporting period remained the standard.
- Use of 2015 Edition CEHRT or 2015 Edition Cures Update was permitted for interoperability functions.
- Performance-based scoring by measure replaced older threshold systems.
- A minimum 60 points were required to successfully attest.
- Participants reported on three self-selected eCQMs plus Safe Use of Opioids eCQM.
2023: Continued Reporting & Focus on Interop
CMS maintained:
- Minimum 90-day reporting.
- CEHRT updated to 2015 Edition Cures Update criteria (for interoperability requirements).
Objectives continued to emphasize:
- Electronic Prescribing
- Health Information Exchange (HIE)
- Provider-to-Patient Exchange
- Public Health & Clinical Data Exchange
2024: Expanded Reporting & New Requirements
For CY 2024 (effective in CMS rules finalized August 2023):
- EHR reporting period increased to a minimum of 180 days.
- CEHRT requirements aligned with updated ONC certification changes.
- Performance-based scoring continued with a 60-point minimum threshold.
- eCQM reporting expanded: participants must report multiple eCQMs over a full year (including opioid and obstetric quality measures).
- New public health data exchange requirements (e.g., Antimicrobial Use and Resistance surveillance) became important for attestation.
Key Themes Over the Years
- Shift from “Meaningful Use” to interoperability: Focus moved toward enhancing the exchange, access, and use of patient data across systems.
- Certified EHR Technology: CEHRT requirements tightened over time, with 2015 Edition and Cures Update becoming standard.
- Reporting period evolution: Started with annual or 90-day periods evolving to longer 180-day requirements.
- Performance-based scoring: Replaced threshold reporting to emphasize measurable performance on interoperability and clinical quality.
The Privacy Rule permits covered entities to disclose PHI, without authorization, to public health authorities or other entities who are legally authorized to receive such reports for the purpose of preventing or controlling disease, injury, or disability.
Resources
Continue to check this site for current ADH Meaningful Use testing requirements and instructions. This is an evolving process as ADH acquires new technology.