Ask a hospital CIO what “meaningful use” means and you’ll likely get a knowing sigh before an explanation. Ask a younger member of the same IT team, and you might get a blank stare followed by “you mean Promoting Interoperability?” Both are talking about the same federal program — it just changed its name, and a good deal of its substance, along the way.

For more than a decade, the Centers for Medicare & Medicaid Services (CMS) has run a program designed to push hospitals and clinicians away from paper charts and toward certified electronic health record (EHR) technology. It started as the Medicare and Medicaid EHR Incentive Programs, became known almost universally by its nickname “meaningful use,” and in 2018 was rebranded as the Promoting Interoperability (PI) program. Understanding how the program got here — and what it currently asks of participants — matters for anyone working in health IT, hospital administration, or clinical informatics.

This article is a policy explainer, not legal or regulatory advice. Program rules, measure sets, and thresholds change from year to year through CMS rulemaking, so anyone attesting to the program should always confirm current requirements directly with CMS rather than relying on a general overview like this one.

The HITECH Act and the birth of meaningful use

The origin point for all of this is the Health Information Technology for Economic and Clinical Health (HITECH) Act, passed in 2009 as part of the American Recovery and Reinvestment Act. HITECH authorized the Medicare and Medicaid EHR Incentive Programs, giving CMS the authority to pay eligible hospitals, critical access hospitals (CAHs), and eligible professionals for adopting, implementing, upgrading, or demonstrating “meaningful use” of certified EHR technology.

The logic behind HITECH was straightforward: EHR adoption in the U.S. was low, health data was fragmented across paper charts and disconnected systems, and a financial incentive was needed to accelerate digitization. CMS and the Office of the National Coordinator for Health IT (ONC) split the resulting work — ONC set certification standards for EHR products, while CMS ran the incentive payment programs and defined what “meaningful use” actually meant in practice.

Meaningful use payments began flowing in 2011, and the program grew quickly: CMS and ONC have reported that hundreds of thousands of eligible hospitals and professionals ultimately participated and received incentive payments over the life of the program. According to CMS, since the broader Promoting Interoperability effort began, nearly 550,000 health care providers have received a payment for participating in the Medicare and Medicaid programs combined — a figure that reflects the scale of the underlying meaningful use effort.

Three stages, one gradually rising bar

Meaningful use was never a single, static checklist. CMS structured it as three sequential stages, each raising expectations for how EHRs were used:

  • Stage 1 (beginning 2011): Focused on data capture and sharing — getting EHRs used at all, with basic functions like recording patient demographics, maintaining problem and medication lists, and generating clinical summaries.
  • Stage 2 (beginning 2014): Raised the bar toward advanced clinical processes, emphasizing health information exchange between providers, electronic prescribing, and giving patients electronic access to their own health information.
  • Stage 3 (beginning 2017, optional before becoming the baseline): Emphasized improved outcomes, more robust interoperability, and expanded patient engagement, including view-download-transmit capabilities and public health reporting.

Each stage required providers to attest that they had met a defined set of objectives and measures, and each built on the certified EHR functionality required by the stage before it. This staged approach was deliberate: CMS wanted providers to walk before they ran, first adopting systems and basic workflows, then gradually pushing toward genuine data exchange rather than digitized silos.

By the mid-2010s, however, a common criticism had emerged from hospitals, physician groups, and health IT vendors alike: the program had become heavy on documentation and reporting burden, and comparatively light on actually solving the interoperability problem it was meant to address. Providers could technically meet meaningful use requirements while patient data remained difficult to move between different health systems.

The 2018 rename: from “meaningful use” to “Promoting Interoperability”

In April 2018, CMS announced it would overhaul the program, and by the fiscal year 2019 hospital inpatient prospective payment system rule, the Medicare and Medicaid EHR Incentive Programs were formally renamed the Medicare and Medicaid Promoting Interoperability Programs. The name change was more than cosmetic — it signaled a deliberate shift in emphasis.

CMS described the goals of the overhaul as reducing the reporting burden on providers, increasing flexibility in scoring, and refocusing the program on interoperability and patient access to their own health data, rather than the more prescriptive, checklist-style attestation that had defined the meaningful use era. In practical terms, this meant a new performance-based scoring methodology (discussed below) replaced much of the older pass/fail, threshold-by-threshold structure.

It’s worth being precise about scope, since this is a common point of confusion: the rename applied to the hospital-facing program. For individual eligible professionals, a separate but related shift had already happened in 2015, when the Medicare Access and CHIP Reauthorization Act (MACRA) sunset the standalone Medicare EHR Incentive Program for eligible clinicians and folded similar requirements into the Merit-based Incentive Payment System (MIPS) as the Promoting Interoperability performance category — one of four categories that make up a clinician’s MIPS composite score, alongside Quality, Cost, and Improvement Activities.

The Promoting Interoperability program was never a single, unified initiative — it has always run on parallel Medicare and Medicaid tracks with different sponsors, rules, and (eventually) different lifespans.

Medicare Promoting Interoperability Program: Applies to eligible hospitals and critical access hospitals paid under the Medicare program, and is administered directly by CMS. For eligible clinicians, the equivalent Medicare-side requirement lives inside MIPS as the Promoting Interoperability performance category rather than as a standalone incentive program.

Medicaid Promoting Interoperability Program: Administered by individual state Medicaid agencies under CMS guidance, this track allowed eligible professionals and hospitals with sufficient Medicaid patient volume to receive incentive payments for adopting, implementing, upgrading, or demonstrating meaningful use of CEHRT. Notably, the last payment year for the Medicaid Promoting Interoperability Program was 2021 — CMS ended the Medicaid incentive payment track as of December 31, 2021, closing out a program that had run in parallel with the Medicare track since 2011.

Because eligibility, reporting periods, and incentive structures differ between the two tracks, hospitals that treat both Medicare and Medicaid patients have historically needed to track requirements separately — attesting to CMS for Medicare purposes and to their state Medicaid agency for Medicaid purposes, where applicable.

What eligible hospitals must report: objectives and measures

Under the current (Medicare) Promoting Interoperability Program structure, eligible hospitals and CAHs report on measures grouped under a small set of objectives rather than the longer list of discrete requirements from the meaningful use era. In broad terms, those objectives cover:

  • Electronic prescribing — generating and transmitting permissible prescriptions electronically through CEHRT.
  • Health information exchange — supporting care coordination through electronic exchange of health information, such as sending and receiving summary-of-care records when patients are referred or transitioned to another care setting.
  • Provider-to-patient access — giving patients (or their authorized representatives) timely electronic access to their own health information.
  • Public health and clinical data exchange — reporting to public health agencies and clinical data registries, covering measures such as syndromic surveillance reporting, immunization registry reporting, electronic case reporting, and electronic reportable laboratory result reporting.

Hospitals attest for an EHR reporting period — historically a minimum continuous 90-day period that the hospital self-selects within the calendar year — during which their certified EHR technology must be in place and actively used to generate the reported data.

Scoring: from pass/fail to a 100-point scale

One of the clearest breaks from the meaningful use era is scoring. Rather than requiring providers to separately clear a series of individual pass/fail thresholds, the Promoting Interoperability Program uses a composite, performance-based scoring methodology.

Under this approach, each measure a hospital reports contributes points toward an overall score out of 100 possible points, with the specific point value of each measure tied to the hospital’s actual performance on it (for example, the percentage of eligible prescriptions sent electronically) rather than simply meeting or missing a fixed bar. CMS has generally required a minimum total score — around 50 points — for a hospital to be considered a “meaningful EHR user” and avoid a downward payment adjustment. Hospitals that fail to report or that score below the required threshold are subject to reduced Medicare payment, since the incentive-payment phase of the program has largely given way to a payment-adjustment (carrot-and-stick) structure in later years.

For clinicians under MIPS, the Promoting Interoperability performance category similarly uses measure-level scoring, which then feeds into that category’s overall weight within the clinician’s total MIPS score — a weight that CMS has set at 25 percent of the total MIPS score in recent performance years, though clinicians should confirm the applicable weighting for any specific performance year directly with the CMS Quality Payment Program.

The CEHRT requirement underpinning everything

None of this works without Certified Electronic Health Record Technology (CEHRT). ONC — not CMS — sets the technical certification criteria that EHR vendors must meet, covering functions like structured data capture, clinical decision support, data export, and secure electronic exchange. CMS then requires PI program participants to use CEHRT that meets the relevant edition of certification criteria in effect for a given reporting period.

This division of labor is intentional and has remained constant since the earliest days of meaningful use: ONC certifies the technology, and CMS incentivizes (and later, requires) its meaningful use. Hospitals and clinicians must confirm that their EHR product holds current certification, that the specific certified functions relevant to their reported measures are active, and that those functions are in place for the entire EHR reporting period being attested — not just on the day of attestation.

A program still in motion

The shift from “meaningful use” to “Promoting Interoperability” reflects a broader pattern in federal health IT policy: the goal of universal EHR adoption has largely been achieved, and the emphasis has moved toward what those systems actually do with the data they hold. That trajectory continued past the 2018 rename, with subsequent rulemaking — including the ONC and CMS interoperability and information-blocking rules — building additional data-sharing and patient-access obligations on top of the PI program’s foundation.

For hospitals, CAHs, and clinicians navigating this landscape, the practical takeaway is that “Promoting Interoperability” is not a one-time compliance exercise but a program that CMS updates through rulemaking on a regular cycle. Anyone responsible for attestation should treat this article as background context and always verify current-year objectives, measures, scoring thresholds, and CEHRT edition requirements against CMS’s own program pages before submitting an attestation.

Frequently Asked Questions

What is the difference between meaningful use and Promoting Interoperability?

They are the same underlying federal program at different points in time. “Meaningful use” was the original name for the Medicare and Medicaid EHR Incentive Programs starting in 2011. CMS renamed the hospital-facing program “Promoting Interoperability” in 2018, alongside a shift toward performance-based scoring and reduced reporting burden.

Who is eligible for the Medicare Promoting Interoperability Program?

Eligible hospitals and critical access hospitals paid under Medicare’s inpatient prospective payment system participate directly in the Medicare Promoting Interoperability Program. Individual eligible clinicians instead report Promoting Interoperability measures as one performance category within MIPS, rather than through a standalone hospital-style program.

Did the Medicaid Promoting Interoperability Program end?

Yes. CMS ended the Medicaid Promoting Interoperability Program, with 2021 as the final payment year and December 31, 2021 as the program’s closing date. The Medicare Promoting Interoperability Program for eligible hospitals and CAHs, and the MIPS Promoting Interoperability performance category for clinicians, continued afterward.

How is the Promoting Interoperability score calculated?

Eligible hospitals report measures across several CMS-defined objectives, and each measure earns points based on actual performance rather than a simple pass/fail threshold, up to a total of 100 possible points. CMS has generally required a minimum score, commonly around 50 points, to be treated as a meaningful EHR user and avoid a downward Medicare payment adjustment.

What does CEHRT mean in the context of this program?

CEHRT stands for Certified Electronic Health Record Technology — EHR software that ONC has certified against a defined set of technical criteria for functions like data capture, clinical decision support, and secure data exchange. Providers must use CEHRT that is properly certified and configured for the entire EHR reporting period they attest to under the Promoting Interoperability Program.