Ensure 2025 Promoting Interoperability Success: Avoid Costly CMS Penalties

• June 07 ,2025

The Centers for Medicare & Medicaid Services (CMS) recently released important updates to the Promoting Interoperability (PI) Program for 2025. This program, formerly known as the Medicare EHR Incentive Program or Meaningful Use, is a cornerstone of the federal strategy to boost health data interoperability and improve patient care outcomes nationwide.

Are you ready to navigate the complexities of the 2025 CMS Promoting Interoperability (PI)Program? Missing its requirements could lead to hefty Medicare payment cuts in 2027, impacting your hospital or practice’s bottom line. Dive into our comprehensive guide to understand the PI Program’s evolution, who it affects, key requirements, deadlines,challenges, and how we ensures your success.

Evolution of the PI Program: From Meaningful Use to Interoperability

Back in 2009, hospitals were buzzing with excitement over Meaningful Use incentives,kickstarted by the HITECH Act to get EHRs up and running. By 2018, CMS flipped the script,renaming it the Promoting Interoperability Program to focus on sharing data, engagingpatients, and coordinating care. Fueled by the 21st Century Cures Act, it’s now all about breaking down data silos and boosting value-based care.

So, what’s shaping 2025? Here’s the rundown:

1. Focus on Interoperability: Prioritizes data sharing across systems, patient accessvia portals/apps, and public health integration.
2. Performance-Based Scoring: Replaced staged requirements with a 70-point minimum threshold in 2025 to avoid IPPS payment penalties.
3. New Measures: Introduced HIE Bi-Directional Exchange (40 points) and mandatoryPublic Health measures like Electronic Case Reporting (eCR) and Antimicrobial Use and Resistance (AUR) Surveillance.
4. Extended Reporting: Requires a 180-day continuous EHR reporting period in 2025,with submission by February 28, 2026, via QualityNet.
5. SAFER Guides: Mandates annual SAFER Guides self-assessments for EHR safety,with a “yes” attestation for all eight guides by 2026.
6. eCQM Reporting: Requires six electronic clinical quality measures (eCQMs) in 2025(11 by 2028) via the Hospital Inpatient Quality Reporting (IQR) Program.
7. Patient Access: Strengthens Provider to Patient Exchange (40 points) for portal/appaccess.
8. FHIR Standards: Emphasizes Fast Healthcare Interoperability Resources (FHIR) forfuture digital quality measures (dQMs) in 2026 IPPS rules.
9. Reduced Burden: Simplifies exclusions, redistributing points (e.g., from Public Health to Patient Access).
10. Public Health Bonus: Offers 5 bonus points for Trusted Exchange Framework and Common Agreement (TEFCA) or clinical data registries.

This transformation positions the PI Program as a cornerstone of value-based care, driving connected, high-quality healthcare.

Who Needs to Comply?

The PI Program impacts a wide range of US healthcare stakeholders, each critical to compliance:

1. Eligible Hospitals and CAHs: Acute care hospitals and critical access hospitals(CAHs) under Medicare’s IPPS or CAH payment systems must comply to avoid 2027 payment reductions.
2. MIPS Eligible Clinicians: Physicians, nurse practitioners, and others under the Merit-based Incentive Payment System (MIPS) rely on PI for 25% of their MIPS score, impacting +9% or -9% payment adjustments.
3. Healthcare IT Leaders: CIOs and IT directors manage CEHRT, ensuring HIE, FHIR, and public health integrations.
4. Practice Managers: Oversee workflows and reporting for measures like e-Prescribing and patient portals.
5. Clinical Staff: Nurses and medical assistants use EHRs for PDMP queries andpatient record updates.
6. Compliance Officers: Ensure HIPAA, Security Risk Analysis (SRA), and no information blocking compliance.

Aligning these roles is essential to maximize reimbursements and deliver exceptional care.

Penalty Risks: Don’t Let Non-Compliance Burn Your Bottom Line!

Non-compliance with the PI Program is a financial game-changer. Hospitals failing to meet the 70-point threshold, submit eCQMs, or complete SRA and SAFER Guides face IPPS payment cuts in 2027, potentially costing large facilities $1M+ annually based on Medicare volume.

Hospitals: Medicare Cuts That Hurt

1. Payment Slash: CMS ties PI compliance to the Annual Payment Update (APU), which adjusts your Medicare reimbursements via the Market Basket Update (MBU), typically around 3.1% for 2025. Fail PI, and you lose 25% of this update. For example, dropping from a 3.1% increase to just 2.325%. For a hospital with $100 million in annual Medicare payments, that’s $775,000 in lost revenue per year, compounding over time.
2. All-or-Nothing Traps: Zero points for e-Prescribing or Public Health if you skip a single measure (e.g., PDMP query, AUR reporting).
3. Real Warning: In 2025, BayCare paid $800,000 for HIPAA violations tied to data security, PI’s Security Risk Analysis could trip hospitals up too.

MIPS Clinicians: Reimbursement Risks

For MIPS-eligible clinicians (e.g., physicians, PAs, NPs), PI is one of four MIPS performance categories, weighted at 25% of your total score in 2025.

1. Payment Adjustments: A low PI score (25% of MIPS) can tank the total below 75, leading to a -9% Medicare Part B cut. For $500K in billings, that’s $45,000 gone.
2. PI Pitfalls: Skip PDMP queries or public health reporting, and the score 0/25 for PI, dragging down your MIPS score.

2025 PI Program Requirements and Scoring

To ace the PI Program in 2025, hospitals and clinicians must excel in four core objectives, report six eCQMs, conduct an SRA, and attest to SAFER Guides during the 180-day reporting period.

Submission Deadline

1. For Eligible Hospitals and Critical Access Hospitals (CAHs)

   1. Submission Deadline: March 13, 2026.This deadline applies to data submissions through the Hospital Quality Reporting (HQR) System.
   2. Includes: Attestations (4 objectives), 6 eCQMs (4 quarters, QRDA I), SRA, SAFER Guides.
   3. Reporting Period: Any 180-day period in 2025.
   4. Notes: Need 70 points to avoid 2027 penalties; keep records 6 years.

2. For MIPS Eligible Clinicians

   1. Submission Deadline: March 31, 2026, at 8:00 p.m. Eastern Time. This deadline applies to submitting 2025 performance data for the Promoting Interoperability category (25% of MIPS score), along with other MIPS categories (Quality, Improvement Activities, Cost), via the Quality Payment Program (QPP) portal.
   2. Includes: PI measures (4 objectives), Immunization & eCR reporting, SRA, SAFER Guides.
   3. Reporting Period: Minimum 180-day period in 2025.
   4. Notes: Avoids -9% 2027 adjustment; exclusions redistribute points.

Below is a concise table summarizing the objectives, followed by details on additional requirements.

1. e-Prescribing: Query PDMP (10 Points)

   What’s Required?

   Before prescribing Schedule II-V controlled substances (e.g., opioids, benzodiazepines) during the 180-day reporting period, query a Prescription Drug Monitoring Program (PDMP) using CEHRT. Prescribers must access real-time patient history within the EHR workflow for all applicable prescriptions. Document queries (date, prescriber, patient) for CMS audits. This aligns with the Safe Use of Opioids eCQM (reported separately via HospitalIQR).

   • Exclusions:

     Available if no PDMP exists in your state or your hospital doesn’t prescribecontrolled substances.

   • Scoring:

     All-or-nothing: Attest “yes” to querying PDMP via CEHRT for all prescriptions to earn10 points. Exclusions or failure to comply score 0. No partial points.
   • Pro Tip: Verify CEHRT’s PDMP integration on the Certified Health IT Product List. Manualqueries outside CEHRT don’t count—integrate now to stay compliant!

2. Health Information Exchange (HIE) (40 Points)

   What’s Required?

   Choose one option to enable seamless data sharing:

   • HIE Bi-Directional Exchange: Attest to sending and receiving patient data (e.g.,discharge summaries, lab results, meds) with unaffiliated providers via CEHRT during the 180-day period. Participate in an HIE or TEFCA, using structured formats(e.g., C-CDA). Attest to three statements:
     1. Active HIE participation for secure, bi-directional exchange.
     2. CEHRT sends/receives structured data.
     3. Exchange improves care coordination.
     4. Keep contracts or data logs for audits.
   • Support Electronic Referral Loops (Alternative): Report two sub-measures:
     1. Sending Health Information (20 points): Use CEHRT to send a structured summary of care (demographics, diagnoses, meds) for at least onetransition/referral.
     2. Receiving Health Information (20 points): Receive and incorporate asummary from another provider, reconciling data (e.g., meds, allergies) intothe EHR. Report numerator/denominator (e.g., % of transitions meeting CMSthresholds, typically 50% for sending, 40% for receiving).
   • Exclusions: Available if no referrals are made; points redistribute to Provider to Patient Exchange.

   • Scoring:

     1. Bi-Directional Exchange: All-or-nothing 40 points for attesting “yes” to all criteria.Exclusions score 0.
     2. Referral Loops: Earn up to 20 points per sub-measure based on performance:(Numerator ÷ Denominator) × 20, capped at 10 points each. Partial points possible(e.g., 40% rate = 8 points per sub-measure).
   • Pro Tip: Use FHIR APIs for smoother exchanges and join TEFCA for potential bonus points under Public Health. Only pick one option—choose what fits your workflow!

3. Provider to Patient Exchange (40 Points)

   What’s Required?

   Enable patients (or authorized reps) to view, download, or transmit health info(demographics, vitals, diagnoses, meds, allergies, labs, discharge summaries) via aCEHRT-enabled portal, app, or FHIR API within 4 business days of an encounter during the180-day period.

   Report:

   1. Numerator/Denominator: Number of unique patients (or their authorized representatives) who are provided timely access to their health information out of all patients discharged during the reporting period.
   2. Timeliness: Percentage of cases where data is available within 4 business days.
   3. CMS requires a minimum performance threshold (e.g., 50% of patients accessing data), though exact percentages may vary based on annual IPPS rules.
   4. Documentation, such as portal usage logs or API access records, must be maintained for audits.

   • Scoring:

     1. Earn up to 40 points: (% patients with access ÷ total discharged) × 40. Meet/exceed CMS threshold (e.g., 50%) for full points; otherwise, points scale (e.g., 40% rate = 32 points).
     2. No exclusions, as this aligns with the 21st Century Cures Act. If Public Health isexcluded, its 25 points shift here, raising the weight to 65 points.
   • Pro Tip: Boost engagement with FHIR-based apps for third-party access and ensure HIPAA-compliant access for patient reps.

4. Public Health and Clinical Data Exchange (25 Points)

   What’s Required?

   Attest to active engagement (registration, testing, or production) for five mandatory measures using CEHRT during the 180-day period:

   1. Syndromic Surveillance: Send ED visit data (HL7 format) to public health for disease monitoring.
   2. Immunization Registry: Submit and query vaccine data (CDC HL7 standards).
   3. Electronic Lab Results: Report infectious disease results (LOINC codes) to public health.
   4. Electronic Case Reporting (eCR): Share real-time disease cases (e.g., via CDC’s eCR Now FHIR app).
   5. Antimicrobial Use/Resistance (AUR): Submit antibiotic use and resistance data to NHSN’s AUR Module. Document engagement (e.g., registration emails, submission logs) for audits.

   Exclusions:

   Available if no local agency accepts data or the hospital doesn’t perform relevant activities (e.g., no lab results).

   Scoring:

   1. All-or-nothing: Attest to all five measures (or valid exclusions) for 25 points. Miss one without exclusion, score 0.
   2. Bonus: Earn 5 points for reporting to a clinical data registry or using TEFCA.
   3. If all measures are excluded, 25 points shift to Provider to Patient Exchange (total 65 points).
   Pro Tip: Integrate with NHSN for AUR and use standardized HL7/FHIR formats to simplify reporting. Check local agency capabilities early!

Additional Requirements

1. Electronic Clinical Quality Measures (eCQMs):

   1. Submit six eCQMs (Safe Use of Opioids, Cesarean Section, Severe Obstetric Complications, plus three you choose) for four quarters via IQR Program by February 28, 2026, using QRDA I format.
   2. Non-scored but mandatory; skipping triggers IPPS penalties.
   3. Scales to 11 eCQMs by 2028.

2. Security Risk Analysis (SRA):

   1. Conduct annual SRA to assess/mitigate data risks, per HIPAA and Protect Patient Health Information Objective.
   2. Complete in 2025; document audits. Mandatory, non-scored; failure causes IPPS penalties.

3. SAFER Guides:

   1. Attest to annual self-assessment of nine SAFER Guides (eight by 2026), covering patient identification, system configuration, etc.
   2. Mandatory, non-scored; failure triggers IPPS penalties.

Challenges to Achieving PI Compliance

The Promoting Interoperability Program is like navigating a high-stakes obstacle course. Here are the key hurdles US providers face:

1. Interoperability Barriers: Integrating legacy EHRs with HIEs or TEFCA requires standardized formats like C-CDA (patient record summaries) or FHIR (smart data-sharing tech).
2. Public Health Integration: Connecting to registries for immunization or syndromic surveillance demands HL7 standards and active engagement, challenging in rural areas with limited infrastructure.
3. Resource Constraints: Small practices often lack IT staff to handle PDMP queries, patient portals, or eCQM reporting.
4. Data Accuracy: Generating clean data for HIE or eCQMs is error-prone without advanced tools.
5. Staff Training: Clinicians need training on workflows like patient portal updates, disrupting operations.
6. Security Compliance: Conducting SRA and SAFER Guides assessments is resource-intensive.

These challenges can lead to missed deadlines or penalties

Secure PI Goals with Comprehensive Support

With 25 years of experience in healthcare IT, KPi-Tech Services is your trusted partner for PI compliance. Our solutions help tackle every challenge, ensuring you meet CMS requirements with ease:

1. EHR Customization: We upgrade EHRs to 2015 Edition Cures Update standards, enabling FHIR APIs for patient portals and C-CDA for HIE data sharing.
2. HIE/TEFCA Integration: Using any interface engine, we connect your EHR to HIEs or TEFCA, unlocking bi-directional exchange and 5 bonus points.
3. Public Health Interfaces: We build HL7-compliant connections for immunization, syndromic surveillance, and AUR reporting to NHSN, ensuring active engagement.
4. Automated Reporting: Our tools streamline eCQM and QualityNet submissions, minimizing errors and saving time.

Get Started with KPi-Tech Today

Don’t let PI Program complexities threaten your reimbursements or patient care. With 25 years of experience, KPi-Tech Services is your US-based partner for 2025 compliance, offering unmatched expertise in FHIR, interface engines, and CMS regulations. Contact us at info@kpitechservices.com.

Download our 2025 PI Compliance Checklist to start your journey!