February 4, 2016
On Jan. 22, 2016, CMS issued a new application and sweeping changes to the Medicare Electronic Health Records (EHR) Incentive Program hardship exception application process. The changes are intended to temporarily ease the burden on providers seeking exemption from the 2017 Medicare meaningful use payment adjustments. Highlights of CMS’ guidance include:
  • CMS may accept Medicare Meaningful Use Hardship Exception Applications for the 2015 EHR Reporting Period from EPs until March 15, 2016, and from qualifying hospitals until April 1, 2016.
  • While CMS has not stated it will issue blanket exemptions to EPs and hospitals who failed to attest to meaningful use in 2015, the language in Section 2.2.d. of the revised Hardship Exception Application leaves open the possibility that CMS will categorically grant exemptions to those applicants asserting Section 2.2.d as the reason for their failure to timely attest to meaningful use for the 2015 EHR Reporting Period.
  • Multiple providers may apply for a Hardship Exception as a group by submitting a single electronic application to CMS that includes each providers’ NPI and CCN.
  • CMS’ revised Hardship Exception Application requires less information from the applicant than the old application, permitting easier filing and processing.
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