All physicians and other Eligible Providers (EPs), whether you have an EHR or not, whether you were successful with Meaningful Use or not, can apply for a hardship exception for the calendar year 2015. A one-year only, liberalized exception is available to all because of the hardship created by CMS’ late release of the 2015 final Meaningful Use rules. By completing this simple process, physicians can avoid a 3% Medicare penalty for the entire year 2017. The deadline for submitting the application is July 1, 2016.
Some key points about this 2015-only opportunity:
- Hardship category 2.2.d was expanded to include hardship created by CMS’s late release of the 2015 Meaningful Use rules. For this category, no supporting documentation is required with the submitted application. However, you should retain a statement describing why you submitted your application, for your records only.
- Physicians may both attest and submit a hardship exception. If you successfully attest, you will be declared a meaningful user and will receive all incentive monies due. So, you can file for the hardship exception as a hedge just in case, for example, an audit finds that something was improper with your attestation.
- For those who are granted the hardship exception, and do not successfully attest, there will be no incentive payment paid. However, you will avoid the 3% Medicare cut during calendar year 2017. The penalty year, 2017, lags the performance year, 2015, by 2 years. The 3% cut applies only to reimbursements under the Medicare Physicians Fee Schedule.
- All hardship exceptions are good for 1 year only. This liberalized exception is available for 2015 only. There are multiple other hardship categories.
Here are the mechanics of completing the application:
Get the Exception form at https://knowledgebase.practicefusion.com/knowledgebase/articles/485845-how-do-i-apply-for-a-meaningful-use-hardship-excep
- Complete this PDF form by typing data right into the form. In the Hardship section, select Hardship Category 2.2.d.
- Save the form, and send it as an email attachment to [email protected].
- Create documentation about the reason and save it for your records. CMS has said that you must create this documentation, but that they will not ask for it.
More information is available from the CMS website at Payment Adjustments and Hardship Information
Eagle Consulting provides support for Meaningful Use. If you have any questions, please call!
Editor’s Note: Subsequent to the publication of this article, CMS has renamed the “Meaningful Use” programs and MIPS “Advancing Care Information” category to “Promoting Interoperability”.
