A Medicare Promoting Interoperability program build is the owner-by-measure matrix, monitoring routine and evidence file that lets an eligible hospital or critical access hospital (CAH) show CMS it met the program's objectives, measures and score. Integral Healthcare Solutions (IHS) has three practice lines (Accreditation Consulting, Compliance Services and Program Development), and this build sits in Program Development. IHS drafts the program, and your hospital attests to CMS. IHS is a consulting firm, not a law firm.
Last updated: November 2026
What does the Medicare Promoting Interoperability Program require of a hospital in 2026?
For CY 2026 an eligible hospital or CAH attesting to CMS must, subject to the exclusions described below, meet all the objectives and measures CMS selected, earn at least 80 points and report over a continuous 180-day period. IHS read 42 CFR 495.24 in the govinfo bulk data (built November 4, 2026; last amended 90 FR 50021, November 5, 2025) and the CY 2026 requirements sheet from a CMS support contractor, updated July 2026, both opened November 5, 2026.
What the regulation says
- Scope and score: under (f)(1)(i), "Except as specified in paragraph (f)(2) of this section," a hospital must "Meet all objectives and associated measures selected by CMS" and earn at least 60 points in 2023 and 2024 and at least 70 in 2025. For 2026 the text reads "In 2026 and subsequent years, earn a total score of at least 80 points."
- Counting: numerators and denominators "increment based on actions occurring during the EHR reporting period selected by the eligible hospital or CAH, unless otherwise indicated."
- Period: in 42 CFR 495.4, for an eligible hospital in CY 2026 and subsequent years the EHR reporting period is "any continuous 180-day period within that calendar year." A CAH has a parallel paragraph.
- Exclusions: a hospital may "exclude a particular measure that includes an option for exclusion" if it meets that measure's criteria and attests; its points "are distributed to other measures as specified by CMS."
- Suppression: beginning with CY 2026, if certain circumstances affect CMS's assessment of a measure, CMS "may, in its sole discretion, suppress the affected measure," giving the maximum points or full credit "as long as the affected measure is reported," or dropping it from the determination "if the affected measure is not scored."
What the CY 2026 sheet adds
Scores add to a total of up to 105 points, and the sheet states: "A score of 0 for an objective or in the numerator of a measure will result in program noncompliance." July 5, 2026 was the last day to begin the 180-day period, so it has passed for CY 2026. Submission is due Monday, March 1, 2027, at 11:59 p.m. PT.
| Objective (CY 2026 sheet) | Points | What the hospital provides |
|---|---|---|
| e-Prescribing | 10 | Numerator and denominator |
| Query of the prescription drug monitoring program | 10 | Yes or no attestation |
| Health information exchange, one of three options | 30 | Referral loops, sending and receiving (15 each), with numerator and denominator; or bi-directional exchange; or exchange under TEFCA (30 each, yes or no) |
| Provide patients electronic access to their health information | 25 | Numerator and denominator |
| Public health and clinical data exchange | 25 | Yes or no attestation at a required level of active engagement for six measures; only one reporting period may be spent in Option 1, pre-production and validation |
IHS inference: the scored rows add to 100 points; the 105 maximum is consistent with the 5 optional bonus points the sheet offers for Option 2 (validated data production) on bonus public health and clinical data exchange measures.
Two groups carry no points but are still required. The first is eCQM reporting: four quarters of CY 2026 data for eight eCQMs, five selected by CMS and three by the hospital. Section 495.4 makes successful reporting of the CMS-selected clinical quality measures, in the form and manner CMS specifies, part of the meaningful EHR user definition. The second is three attestations that must be Yes: the SAFER Guides, the Security Risk Analysis measure (analysis plus risk management activities) and, under 42 CFR 495.40, that for CY 2022 and later the hospital "did not knowingly and willfully take action (such as to disable functionality) to limit or restrict the compatibility or interoperability of certified EHR technology."
What happens to a hospital that is not a meaningful EHR user?
Under 42 CFR 412.64(d)(3)(i), a subsection (d) hospital that is not a meaningful EHR user for the applicable period and does not receive an exception has "three-fourths of the percentage increase in the market basket index" reduced, and for fiscal year 2017 and later "by 100 percent." Under 42 CFR 413.70, inpatient CAH payment of 101 percent of reasonable costs becomes 100 percent for cost reporting periods beginning in FY 2017 and later if the CAH is not a qualifying CAH for the applicable period.
Section 412.64(d)(4) lets the Secretary exempt a hospital "on a case-by-case basis" where compliance "would result in a significant hardship," on an application that meets one of the listed criteria (renewable annually, no more than 5 years). It also requires an exemption where the hospital's certified EHR technology was decertified and the hospital made a good faith effort to obtain other technology; applications are due July 1 of the year before the payment adjustment year or a later date CMS specifies. Section 495.4 adds that a hospital is not a meaningful EHR user in a payment adjustment year "if the HHS Inspector General refers a determination that the eligible hospital or CAH committed information blocking as defined at 45 CFR 171.103 during the calendar year of the EHR reporting period."
Who needs this build and what triggers it?
Any hospital attesting to CMS needs a named owner and source for each measure. Four situations start the work:
- A reporting year is under way with no owner named per measure. For CY 2026 the sheet's deadline is March 1, 2027.
- The hospital missed or nearly missed the 80-point test.
- An EHR vendor or module change is planned. The attestation must specify the certified EHR technology used (42 CFR 495.40(b)(2)(i)(A)).
- CMS review. Section 495.40(c) says CMS "may review" the demonstration and that hospitals "must keep documentation supporting their demonstration of meaningful use for 6 years."
How IHS helps
IHS reads the regulation and sheet together as tests to pass: all selected measures met, at least 80 points, a 180-day period, eight eCQMs, Yes on the unscored attestations and no zero numerator. That is IHS's reading, not a CMS statement.
What IHS drafts
- A measure-ownership matrix: owner, backup, data source and evidence location for each measure and unscored attestation.
- An attestation evidence file index with a 6-year retention entry.
- A monthly numerator and denominator monitoring procedure, so a low numerator is seen during the 180-day period and not after it.
- A calendar for the security risk analysis and SAFER Guides, an eCQM checklist and a reporting-period decision memo template.
What you supply
Your certified EHR product and CMS EHR Certification ID, prior submissions, EHR measure reports, security risk analysis records, registry records and named staff.
The real limit
IHS does not submit through the HQR Secure Portal, certify technology or contact CMS. Measures and points come from each year's sheet. This page covers the hospital program only, not the clinician program.
What to have ready
- Certified EHR technology product name and CMS EHR Certification ID (42 CFR 495.40(b)(2)(i)(A)).
- Your last score against the 80-point test (42 CFR 495.24(f)(1)(i)(D)).
- The measures CMS selected for the year and who owns each now (42 CFR 495.24(f)(1)(i)(A)).
- Numerator and denominator reports for each measure that needs them, and your yes or no attestation records (CY 2026 sheet).
- Your health information exchange option and public health engagement records.
- Any exclusion claimed and its support (42 CFR 495.24(f)(2)); any CMS suppression notice (495.24(f)(3)).
- Your 180-day dates and each quarter's eCQM files (42 CFR 495.4).
- Security risk analysis, risk management and SAFER Guides records, and your basis for the interoperability attestation (42 CFR 495.40(b)(2)(i)(K)).
A free introductory call is the place to walk through this list.
How it compares
Four CMS hospital programs have separate texts and payment consequences.
| Program | Governing text | What the text says is at stake |
|---|---|---|
| Promoting Interoperability (this page) | 42 CFR 495.24(f); 412.64(d)(3) | Meaningful EHR user status; three-fourths of the market basket increase reduced by 100 percent |
| Hospital Inpatient Quality Reporting | 42 CFR 412.140; 412.64(d)(2) | For fiscal year 2015 and later, market basket increase reduced by one-fourth if a subsection (d) hospital does not submit quality data quarterly as CMS specifies |
| Hospital Outpatient Quality Reporting | 42 CFR 419.46 | Regulation cites statutory authority for a 2.0 percentage point reduction in the OPD fee schedule increase factor for a subsection (d) hospital that does not submit required data |
| Hospital Value-Based Purchasing | 42 CFR 412.160 to 412.168 | Value-based incentive payments, under the conditions in 412.162, to a hospital that meets or exceeds the performance standards for a fiscal year |
For a related build, see the hospital QAPI program build.
What it costs
The regulation and the sheet state no fee for participating, so the costs are consulting and your staff time.
- Authority fees: none stated in the text IHS opened. The exposure is the payment reduction described above.
- Consulting fees: IHS scopes each engagement after a free introductory call. The scope moves with the number of hospitals and EHR products and the measures lacking an owner or data source.
- Your internal time: quality, IT, compliance and clinical leads review the matrix, pull monthly reports and adopt the procedures. IHS publishes no staff-hour estimate.
What this is not
- It is not legal advice. IHS is a consulting firm, not a law firm.
- It is not a submission service. Your hospital attests, and IHS does not contact CMS.
- It is not technology certification or a guarantee of a score or a CMS review outcome.
Frequently asked questions
What is the Medicare Promoting Interoperability Program for hospitals?
It is the CMS program under 42 CFR Part 495 that decides whether a hospital attesting to CMS is a meaningful EHR user. Section 495.24(f) applies to eligible hospitals and CAHs attesting to CMS for 2023 and subsequent years.
How many points do hospitals need in 2026?
At least 80. Section 495.24(f)(1)(i)(D) sets that score for 2026 and subsequent years, and the CY 2026 sheet puts the maximum at 105. The regulation set 60 for 2023 and 2024 and 70 for 2025.
Which measures are scored and how many points are they worth?
On the CY 2026 sheet: e-Prescribing 10, the drug monitoring program query 10, health information exchange 30 under any of three options, provider to patient exchange 25 and public health and clinical data exchange 25.
What happens if a measure scores zero?
The CY 2026 sheet states: "A score of 0 for an objective or in the numerator of a measure will result in program noncompliance." Track numerators monthly so a zero is seen while the period is open.
Can we exclude a measure?
Only a measure that includes an option for exclusion, and only if the hospital meets that measure's criteria and attests to the exclusion (section 495.24(f)(2)(i)). Keep the support in the evidence file.
What does CMS mean by suppressing a measure?
Beginning with CY 2026, CMS may in its sole discretion suppress a measure affected by certain circumstances (section 495.24(f)(3)), giving full credit or maximum points if it is reported, or dropping it if it is not scored.
What evidence should be kept for attestation?
Section 495.40(c)(2) requires documentation supporting the demonstration for 6 years. IHS would index the numerator and denominator reports, attestation and exclusion records, any suppression notice, security risk analysis records and the reporting-period memo.
Does IHS submit the attestation or contact CMS?
No. The hospital attests and submits through the HQR Secure Portal. IHS does not contact, submit to or correspond with CMS.