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The deadline is fast approaching to file for a Hardship Exception to avoid the 2016 Medicare EHR payment adjustment. If your provider successfully attested for the 2014 reporting period, you do not have to file an application. If a provider did not successfully demonstrate meaningful use in 2014 in either the Medicare or Medicaid EHR Incentive Programs, it will result in a reduction of 2% to the physician fee schedule amounts for the 2016 payment year. The deadline for filing a Hardship Exception Application is by 11:59 PM EDT on July 1, 2015 for all eligible professionals.
Only the following doctors are required to participate in the Medicare EHR Incentive Program:
- Doctor of medicine or osteopathy
- Doctor of optometry
- Doctor of dental surgery or dental medicine
- Doctor of chiropractic
- Doctor of podiatry
Automatic exceptions are made for the following groups of providers and you do not have to file an exception application.
Specialties - If you are classified in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) as having one of the following 5 specialty codes as your primary area of practice, you DO NOT need to submit this form.
- Anesthesiology (05)
- Diagnostic Radiology (30)
- Interventional Radiology (94)
- Nuclear Medicine (36)
- Pathology (22)
New EPs - New EPs are defined as those who do not submit Medicare claims for two years prior to the payment adjustment year. Therefore, if you do not have any Medicare claims for calendar year 2014 and 2015, you DO NOT need to submit this form; you will be granted a hardship exception and are automatically exempt from the 2016 payment adjustment.
Hospital-Based EPs - If you are a hospital-based EP for 2014 or 2015, you DO NOT need to submit an application form. CMS guidelines state that if you perform 90% or more of your covered professional services in either the inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital, you are determined to be hospital-based and are not eligible to receive payment for the EHR Incentive Program and are exempt from the payment adjustment.
To file a hardship exception, you must:
- Show proof of a circumstance beyond your control.
- Explicitly outline how the circumstance significantly impaired your ability to meet meaningful use.
- Provide supporting documentation for certain hardship exception categories. CMS will review applications to determine whether or not a hardship exception should be granted.
Here are some examples of exception reasons but for a full list please use the link below to review the application:
- Infrastructure: Eligible professionals must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).
- New Eligible Professionals: Newly practicing eligible professionals who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments. Thus eligible professionals who began practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating meaningful use in calendar year 2016 to avoid payment adjustments in 2017.
- Unforeseen Circumstances: Examples may include a natural disaster or other unforeseeable barrier.
- 2014 EHR Vendor Issues: The eligible professional’s EHR vendor was unable to obtain 2014 certification or the eligible professional was unable to implement meaningful use due to 2014 EHR certification delays.
- Patient Interaction: Lack of face-to-face or telemedicine interaction with patient, or lack of follow-up need with patients.
For more information and helpful tips, use these links:
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/HardshipException2016_EP_Application_MultipleNPIs.pdf
