The Medicare Promoting Interoperability (PI) Program is an initiative managed by the Centers for Medicare & Medicaid Services (CMS) designed to modernize the United States healthcare system. This program primarily encourages the widespread, meaningful use of Electronic Health Records (EHRs) by specific healthcare facilities. It emphasizes that providers must actively use the technology to improve patient care and health data exchange. The current PI Program evolved directly from the earlier Medicare and Medicaid Electronic Health Record Incentive Programs, commonly known as “Meaningful Use.”
Foundational Goals of Promoting Interoperability
The core purpose of the Promoting Interoperability Program is to drive improvements in the quality, safety, and efficiency of healthcare delivery. This initiative aims to move the health system beyond digitizing paper charts toward a connected, data-driven environment. A primary objective is to enhance health information exchange (HIE) between different healthcare settings, ensuring patient data follows them seamlessly across various providers.
The program works to improve patient outcomes by mandating the standardized use of health data. Seamless data exchange supports better coordination of care, particularly during transitions, such as when a patient is discharged from a hospital. The legislative intent for this push toward digital health originated with the Health Information Technology for Economic and Clinical Health (HITECH) Act, passed as part of the American Recovery and Reinvestment Act of 2009. This foundational law established the framework for incentivizing the adoption of certified health information technology.
The goals prioritize advancing the functionality of electronic health record systems to support better decision-making by clinicians. Promoting Interoperability also focuses on empowering patients by mandating timely and easy access to their personal health information. By standardizing how data is captured, stored, and shared, the program ultimately seeks to reduce administrative burden and increase the security and privacy of sensitive health records.
Eligible Participants and Required Technology Standards
The Medicare PI Program specifically targets healthcare facilities that receive payments under the Medicare program. The two main categories of participants are Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs). These hospitals must successfully meet the program’s reporting requirements annually to avoid downward adjustments to their Medicare reimbursement.
A central requirement for participation is the mandatory use of Certified Electronic Health Record Technology (CEHRT). The system must be certified by an authorized body to meet specific functional and security standards set by the Office of the National Coordinator for Health Information Technology (ONC). The certification process ensures that the technology can support the program’s objectives, such as e-prescribing and secure health information exchange.
Historically, the program required systems to meet criteria from specific “editions,” such as the 2015 Edition Cures Update. Hospitals must use the most current, federally-approved health IT certification criteria. This ensures providers are using technology capable of the advanced features necessary for robust interoperability and patient engagement. Hospitals must submit their EHR system’s identification code from the Certified Health IT Product List (CHPL) to verify compliance.
Core Measurement Categories and Objectives
To demonstrate meaningful use of CEHRT, participating hospitals must report on measures across four primary objective categories that collectively form their PI score.
Electronic Prescribing
The Electronic Prescribing objective measures the use of CEHRT to generate and transmit prescriptions electronically, which improves efficiency and reduces medication errors. This moves prescribing away from paper and fax methods toward a secure electronic workflow.
Health Information Exchange (HIE)
The Health Information Exchange (HIE) category focuses on the secure, bi-directional sharing of patient data between unaffiliated healthcare entities. Measures track the electronic sending of care summaries upon transition of care and the electronic receipt and reconciliation of summaries from outside providers. Providers must choose options, such as participating in a health information exchange network, to meet the requirements.
Provider to Patient Exchange
The third category, Provider to Patient Exchange, is dedicated to patient access and engagement. Hospitals must ensure patients have timely electronic access to view, download, and transmit their health information. This includes supporting the use of application programming interfaces (APIs) so patients can access their records using third-party mobile applications.
Public Health and Clinical Data Exchange
The final category is Public Health and Clinical Data Exchange, which requires eligible hospitals to electronically report data to public health agencies. This reporting helps track health trends and conditions, including syndromic surveillance, immunization registry reporting, and electronic case reporting. Hospitals must meet minimum thresholds and successfully attest to additional requirements, such as completing a Security Risk Analysis and using the Safety Assurance Factors for EHR Resilience (SAFER) Guides.
Financial Adjustments for Participation
The Medicare PI Program is enforced through financial adjustments tied to Medicare reimbursement. Unlike the initial years of the Meaningful Use program, which offered incentive payments, the current program primarily operates by applying payment reductions for non-compliance. Eligible Hospitals and Critical Access Hospitals must successfully meet all PI requirements annually to avoid these financial penalties.
For an Eligible Hospital that fails to demonstrate meaningful use, the payment adjustment is applied as a reduction to the Inpatient Prospective Payment System (IPPS) payment rate. This reduction significantly lowers the annual percentage increase the hospital would otherwise receive. Critical Access Hospitals face a different financial consequence: their Medicare reimbursement is reduced from 101 percent of their reasonable costs to 100 percent.
The program operates on a delayed cycle. Data submitted by a hospital during a given calendar year will affect their Medicare payment determination for a subsequent fiscal year. This lag time means that failure to comply with reporting requirements today will result in a financial penalty applied years later. The potential for a negative payment adjustment serves as the primary mechanism to ensure hospitals maintain the advanced use of certified electronic health record technology.