Quality data is critical to informing public health actions. That’s why every day, state and local health departments analyze and use health system data to protect and promote community health.
They do this by detecting and monitoring disease trends, identifying health disparities among different demographics, and deploying resources to improve health outcomes. For example, if data reveals higher rates of hepatitis A in certain populations, the health department may plan interventions, such as public health campaigns or vaccination drives, that target the communities that need them most.
The Centers for Medicare & Medicaid Services (CMS), the nation’s largest health care payer, drives much of this data exchange by giving hospitals and clinicians incentives to electronically send health and disease information to public health agencies. But surprisingly, the quality, timeliness and comprehensiveness of this critical information is largely unknown.
Why? In large part because current CMS metrics for public health and clinical data exchange only require a binary response: yes or no. Hospitals and clinicians participating in these incentive programs are asked to simply attest to whether they’re completing essential tasks to promote interoperability—such as sending electronic case reports or immunization data to public health agencies using certified electronic health record (EHR) technology. But that’s it.
So it’s encouraging that in recent years, CMS has prioritized figuring out how to leverage its payment programs to measurably improve the exchange of public health data. In the proposed 2026 payment policies for hospitals and clinicians, CMS expressed interest in “new measure concepts for public health that would allow us to better focus on aspects of the data quality of public health reporting.”
Specifically, the agency asked the public about which aspects of data quality and usability are most appropriate and valuable to measure, such as timeliness and completeness of reporting. CMS also wanted input on how to define “complete data” and different ways to evaluate providers’ performance on exchanging public health and clinical data. These questions build off ones asked in CMS’ 2025 proposed rules for hospitals and clinicians.
This is an area where the agency can and should continue to incentivize more timely reporting of data critical to protecting people’s health. CMS has an opportunity to improve that timeliness through the development and implementation of meaningful performance measures. The agency can do this as part of its Inpatient Prospective Payment System (IPPS) for eligible and critical access hospitals, and it can do the same for eligible clinicians through its Merit-Based Incentive Payment System (MIPS).
Timelier data can help public health agencies act more quickly to identify health threats, such as increased rates of Hepatitis A in a particular population, and allocate limited resources more effectively. Additionally, public health agencies could share community-level information with providers, helping inform screening, vaccinations, and other clinical practices.
Current attestation-based measures have led to some improvements
CMS’ use of public health and clinical data exchange measures has resulted in notably improved rates of data reporting to public health agencies. For example, when the immunization registry reporting measure became a requirement in Stage 2 of the Meaningful Use Program, the successor to the Promoting Interoperability (PI) category within MIPS, electronic reporting of immunization information increased by more than 40% from 2011 to 2014 among eligible professionals.
As another example, a recent data brief from the Department of Health and Human Services’ Assistant Secretary for Technology Policy highlighted that “Rates of electronic case reporting have increased substantially since reporting on this measure became required in the PI program in 2022, increasing from 53% in 2021 to 84% in 2024.” And this has been borne out in The Pew Charitable Trusts’ research. One of Pew’s key takeaways from hundreds of interviews with public health and state leaders across the country was that the PI program “has been a huge driver in incentivizing healthcare organizations to report electronically.”
However, although attestation-based measures have been important steps forward, major gaps remain in CMS’ ability to assess the quality, timeliness and completeness of data reported to public health agencies. This is where performance metrics can help.
Performance measures can build on success of attestation-based measures
The time has come for CMS to implement performance measures—or quantitative metrics—for public health and clinical data exchange. This means shifting from attestation-based measures to performance-based measures.
In its response to CMS’ most recent request for information, Pew highlighted a performance-based immunization registry reporting measure that could be particularly effective in encouraging timely information sharing. Specifically, the measure calculates the proportion of immunizations administered that are successfully reported to public health agencies within one day, using certified EHR technology. To continue to driving improvements in timely and complete reporting, CMS could set a performance threshold for providers to meet and gradually raise that benchmark, with the goal of increasing the proportion of administered immunizations that are reported to public health agencies within one day. Pew also recommended implementation of this measure in response to a similar request for information on proposed payment policies for hospitals.
This measure is a win-win. Pew’s research and in-depth interviews with more than 50 subject matter experts from throughout the country have demonstrated that it could benefit public health and be implemented in such a way that the burden on hospitals and clinicians is relatively low. The performance measure is also supported by leading public health informatics organizations, such as the Joint Public Health Informatics Task Force, a coalition of 14 national public health associations, including the American Immunization Registry Association.
Once implemented, the measure’s benefit to public health would be significant. By incentivizing the timeliness of every report, vaccine histories in immunization registries would be more complete and questions about population-based trends in vaccination coverage could be answered with greater accuracy. Providers and patients would have access to up-to-date vaccine histories that inform health care delivery at the point of care. Questions about who is eligible to be vaccinated, the current level of population immunity, and the safety and effectiveness of vaccines could be confidently answered on a daily basis.
Although this is just one measure under consideration by CMS, it’s a meaningful and feasible one. As such, Pew urges the agency to start developing and testing the performance-based measure as soon as possible. Doing so will advance CMS’ vital and ongoing role in supporting public health data exchange, an effort that is certain to help states and the communities they serve.
Sheri Doyle is a senior officer of public health data improvement at The Pew Charitable Trusts.
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