Promoting Interoperability

CMS Promoting Interoperability and Merit-based Incentive Payment System

The Centers for Medicare & Medicaid Services (CMS) have modified existing public health reporting requirements for eligible clinicians (ECs) participating in the Merit-based Incentive Payment System (MIPS) and eligible hospitals (EHs) and critical access hospitals (CAHs) participating in Promoting Interoperability Program (PIP) for calendar year (CY) 2026.

The CT DPH 2026 Project Status Letter (PIP & MIPS) is available here: 

For your reference, the 2025 Project Status Letter is here:

CMS Updates

In CY 2026, there continue to be two options for active engagement for ECs, EHs, and CAHs:

  • Option 1 Pre-production and Validation. The eligible participant has completed registration with DPH to submit data and is engaged in testing and validation or waiting for an invitation to begin testing and validation. Please note that there are additional requirements to be met during Option 1 engagement.
  • Option 2 Validated Data Production. The eligible participant has completed testing and validation of the electronic submission and its electronically submitting production data (clinical level data) to the PHA or CDR.

If an EC/EH/CAH is already engaged with DPH programs for these public health reporting measures, they start 2026 in that same option. To qualify for Option 2, production has to occur over a 180-day period of time in 2026.

The specific requirements for ECs/EHs/CAHs for public health reporting to DPH are as follows:

  • For the ECs participating in the 2026 MIPS, the regulation requires reporting of two measures associated with the Public Health and Clinical Data Exchange Objective: Immunization Registry Reporting, and Electronic Case Reporting. An EC must be engaged or newly engaged in Option 1 or be engaged in Option 2 to receive points. If ECs cannot meet these measures, they must request an exclusion or hardship based on CMS criteria.
  • For the EHs and CAHs participating in the 2026 Medicare PIP, the regulation requires reporting of four Public Health and Clinical Data Exchange Objective measures: Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting, and Electronic Reportable Laboratory Result Reporting. An EH or CAH must be engaged or newly engaged in Option 1 or be engaged in Option 2 to receive points. If EHs or CAHs cannot meet these measures, they must request an exclusion or hardship based on CMS criteria.

Additional information for ECs can be found in the CMS Quality Payment Program Resource Library. Additional information for EHs and CAHs can be found on the Promoting Interoperability Programs website.

DPH Contacts

To register for submitting data to DPH for one of the following performance measures, please see the link or email below:

Contact information is on the linked pages. Please follow instructions or email contacts about registration and/or verification for attestation.

For Antimicrobial Use and Resistance Surveillance, the requirement is reporting to the CDC's National Healthcare Safety Network (NHSN) system. For help with NHSN, please email NHSN@cdc.gov.

Exclusions

If a participant is taking an exclusion, they are not required to register with DPH. If registered, the participant is considered in active engagement Option 1 and cannot claim exclusion. DPH is not involved in granting exclusions. To follow-up with CMS directly, see information below:

  • For MIPS: Eligible clinicians may contact the Quality Payment Program help desk for assistance at qpp@cms.hhs.gov or call 1-866-288-8292.
  • For PIP: Medicare eligible hospitals may contact the QualityNet help desk for assistance at qnetsupport@hcqis.org or call 1-866-288-8912.
  • For AU and AR Surveillance measures: Eligible clinicians and critical access hospitals may access qualitynet.cms.gov. Click the "Help" tab in the upper right hand corner, select "Q&A Tool Main Page", select "Ask a Question" choose: PI - Promorting Interoperability" from the Program dropdown menu or call 1-844-472-4477.

Information for EHR Vendors and Healthcare Organizations

PIP and MIPS require the use of certified EHR technology (CERHT) that meets ONC Certification Criteria for Health IT. The CT DPH uses Health Level 7 (HL7) electronic initial case report (elCR) and Reportability Response (RR) standards for electronic case reporting (eCR). Please ensure that your Electronic Health Record (EHR) product is capable of supporting the HL7 implementation guides shown below:

  • HL7 Clinical Document Architecture (CDA) implementation guides
    (https://www.hl7.org/implement/standards/product_brief.cfm?product_id=436)
    • eICR R1.1 (HL7 CDA® R2 Implementation Guide: Public Health Case Report Release 2: the Electronic Initial Case Report (eICR) Release 1, STU Release 1.1 - US Realm)

    • eICR R3.1.1 (HL7 CDA® R2 Implementation Guide: Public Health Case Report - the Electronic Initial Case Report (eICR) Release 2, STU Release 3.1.1 - US Realm)

    • RR R1.1 (HL7 CDA® R2 Implementation Guide: Reportability Response, Release 1, STU Release 1.1 - US Realm)

  • HL7 Fast Healthcare Interoperability Resources (FHIR) Implementation Guide
    (http://hl7.org/fhir/us/ecr/STU2.1)

    • FHIR eCR R2.1.2 (HL7 FHIR® Implementation Guide: Electronic Case Reporting (eCR), Release 2.1.2 - US Realm)

Other Requirements

Senders must conduct full triggering of eICRs (triggering for all conditions) by implementing Electronic Reporting and Surveillance Distribution (eRSD) version 3 or higher.

Please note: All existing eICR 1.1 senders should update to eICR 3.3.1 by June 1, 2026. Any new product implementation after January 1, 2026 must use eICR R.3.1.1.

Please use the links below to obtain more information regarding CERHT.

Helpful Websites and Resources:

DPH encourages you to frequently check this Connecticut Department of Public Health's Promoting Interoperability Website for updates.