Recently, the Centers for Medicare & Medicaid Services (“CMS”) published additional guidance for Medicare eligible hospitals seeking to avoid the 2016 Medicare EHR Incentive Program payment adjustment.
Medicare eligible hospitals can avoid the 2016 payment adjustment by taking action by April 1 and applying for a 2016 hardship exception.
The hardship exception application and instructions for Medicare eligible hospitals are available on the EHR Incentive Programs website and outline the specific types of circumstances that CMS considers to be barriers to achieving meaningful use and how to apply.
To file a hardship exception, Medicare eligible hospitals must:
- Show proof of a circumstance beyond the eligible hospital’s control; and
- Explicitly outline how the circumstance significantly impaired the eligible hospital’s ability to meet meaningful use.
Supporting documentation must also be provided. CMS will review applications to determine whether or not a hardship exception should be granted.
As a reminder, the application must be submitted electronically or postmarked no later than 11:59 p.m. ET on April 1, 2015 to be considered.
If approved, the exception is valid for one year. If the eligible hospital claims a hardship exception for the following payment year, a new application must be submitted.
If you have questions regarding the hardship exception, please contact:
- Jeff Short at (317) 977-1413 or jshort@wp.hallrender.com;
- Ammon Fillmore at (317) 977-1492 or afillmore@wp.hallrender.com; or
- Your regular Hall Render attorney.
