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CMS Launches Important Changes to the Medicare EHR Incentive Program Hardship Exception Process

Today, CMS launched important changes to the Medicare EHR Incentive Program hardship exception process that will reduce burden on clinicians, hospitals, and critical access hospitals (CAHs). These changes are a result of recent Medicare legislation – the Patient Access and Medicare Protection Act (PAMPA), Pub. L. No. 114-115 – and our ongoing efforts to improve the program.

CMS has posted new, streamlined hardship applications, reducing the amount of information that eligible professionals (EPs), eligible hospitals, and CAHs must submit to apply for an exception. The new applications and instructions for a hardship exception from the Medicare Electronic Health Records Incentive Program 2017 payment adjustment are available here.

This new, streamlined application process is the result of PAMPA, which established that the Secretary may consider hardship exceptions for “categories” of EPs, eligible hospitals, and CAHs that were identified on CMS’ website as of December 15, 2015. Prior to this law, CMS was required to review all applications on a “case-by-case” basis.

Importantly, EPs, eligible hospitals, and CAHs that wish to use the streamlined application must submit their application according to the timeline established in PAMPA:

  • Eligible Professionals: March 15, 2016
  • Eligible Hospitals & CAHs: April 1, 2016

Please note: CAHs should use the form specific for the CAH hardship exceptions related to an EHR reporting period in 2015. CAHs that have already submitted a form for 2015 are not required to resubmit.

In addition, we have heard from stakeholders that they would like a more efficient approach for submitting applications from groups of providers. Following Congress’ efforts in PAMPA, we have reviewed our administrative authorities and determined that groups of providers may apply for a hardship exception on a single application. Under the group application, multiple providers and provider types may apply together using a single submission. The hardship exception categories are the same as those applicable for the individual provider application.

Providers will have the option to submit an electronic file (in excel or csv formats) with all National Provider Identifiers (NPIs) or CMS Certification Numbers (CCNs) for providers within the group or use a multiple NPI or CCN form to submit their application. In addition, facilities which include both inpatient and outpatient settings may include both the individual NPIs for any eligible professionals and the CCN for the eligible hospitals and CAHs on the same single submission for their organization.

We look forward to further simplifying and continuing to improve the EHR Incentive Programs in collaboration with the provider community and Congress.

January 22, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Submit Applications for EHR Penalty Reconsiderations by November 30

In the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated that payment adjustments should be applied to Medicare eligible professionals, eligible hospitals, and critical access hospitals (CAH) that are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program. Payment adjustments for eligible hospitals began on October 1, 2014.

2016 Payment Adjustments for Medicare Eligible Hospitals
Eligible hospitals receive the Medicare payment adjustment amount that is tied to a specific fiscal year. For fiscal year 2016, Medicare eligible hospitals that were not meaningful EHR users in 2014, and were not granted a hardship exception, were subject to a payment adjustment beginning October 1, 2015. This payment adjustment is applied as a reduction to the applicable percentage increase to the Inpatient Prospective Payment System (IPPS) payment rate, thus reducing the update to the IPPS standardized amount for these hospitals.

2016 Reconsiderations Application Due November 30
For eligible hospitals who received a Medicare payment adjustment letter for 2016, and believe their hospital was subject to a payment adjustment in error, applications for payment adjustment reconsideration for fiscal year 2016 must be submitted electronically or postmarked by 11:59 PM EST on November 30.

The instructions and application for a payment adjustment reconsideration are available on the Payment Adjustments & Hardship Information page of the CMS website.

November 24, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

New EHR Incentive Program FAQs from CMS

On October 6, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To keep you informed of changes to the programs and how to participate in 2015, CMS has also released three new FAQs providing clarification on how to attest to certain measures for health information exchange, patient electronic access, and other objectives that require patient action.

FAQ 12817
Question: For the Health Information Exchange objective for meaningful use in 2015 through 2017, may an eligible professional (EP), eligible hospital or critical access hospital (CAH) count a transition of care or referral in its numerator for the measure if they electronically create and send a summary of care document using their CEHRT to a third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document?

Answer: Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party organization is involved so long as:

  • The summary of care document is created using certified EHR technology (CEHRT);
  • The summary of care document is transmitted electronically by the EP, eligible hospital or CAH to the third party organization…read the full FAQ.

FAQ 12821
Question: If multiple eligible professionals or eligible hospitals contribute information to a shared portal or to a patient’s online personal health record (PHR), how is it counted for meaningful use when the patient accesses the information on the portal or PHR?

This answer is relevant to the following meaningful use objectives: Patient Specific Education and Patient Electronic Access measure 2.

Answer: If an eligible professional sees a patient during the EHR reporting period, the eligible professional may count the patient in the numerator for this measure if the patient (or an authorized representative) views online, downloads, or transmits to a third party any of the health information from the shared portal or online PHR. The same would apply for an eligible hospital or CAH if a patient is discharged during the EHR reporting period. If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. The respective eligible professional, eligible hospital, or CAH must have contributed at least some of the information identified in the Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 final rule (80 FR 62807 through 62809) to the shared portal or online PHR for the patient. However, the respective provider need not have contributed the particular information that was viewed, downloaded, or transmitted by the patient. …Read the full FAQ.

FAQ 12825
Question: In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?

Answer: Yes. This transitive effect applies to the Secure Electronic Messaging objective, the 2nd measure of the Patient Electronic Access (View, Download and Transmit) objective, and the Patient Specific Education objective.

If a patient sends a secure message about a clinical or health related subject to the group practice of their EP, that patient can be counted in the numerator of the Secure Electronic Messaging measure for any of the EPs at the group practice who use the same certified electronic health records technology (CEHRT) that saw and patient during their EHR reporting period.

Similarly, if a patient views, downloads or transmits to a third party the health information that was made available online by their EP, that patient can be counted in the numerator of the 2nd Patient Electronic Access measure for any of the EPs in that group practice who use the same CEHRT and saw that patient during their EHR reporting period.

If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. … Read the full FAQ.

For more information on accurately calculating the numerator for measures, please visit FAQ 8231.

November 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Learn about New Requirements for Participation in EHR Incentive Programs

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) recently announced the release of final rules for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs and the 2015 Edition Health IT Certification Criteria. The rules will be published on October 16, 2015, and are currently on display in the Federal Register.

The EHR Incentive Programs final rule provides new criteria that eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must meet in order to successfully participate in the EHR Incentive Programs. The final rule outlines program requirements in 2015 through 2017 (Modified Stage 2) and Stage 3 in 2018 and beyond, and includes a comment period for Stage 3.

The 2015 Edition Health IT Certification Criteria final rule builds on past editions of adopted health IT certification criteria, and includes new and updated IT functionality and provisions that support the EHR Incentive Programs’ care improvement, cost reduction, and patient safety across the health system.

EHR Incentive Programs Final Rule Provisions
Through the new requirements of the EHR Incentive Programs, CMS will expand meaningful use of certified EHR technology to promote health information exchange and improved outcomes. The rule also includes changes to the structure of the EHR Incentive Programs to improve efficiency, effectiveness, and flexibility.

Major policy provisions include:

  • Program modifications to reduce reporting burden, eliminate redundant and duplicative reporting, and to better align the objectives and measures of meaningful use with the Stage 3 requirements.
  • A revised single set of objectives and measures, including a reduction of the overall number of objectives to which a provider must attest.
  • Changes in EHR reporting periods, including a shift to calendar year for all providers and 90-day reporting for 2015.
  • Revisions to attestation and payment adjustment deadlines.
  • Optional Stage 3 reporting in 2017.

For more information about the EHR Incentive Programs final rule, view the Final Rule Fact Sheet that highlights key changes to the EHR Incentive Programs.

To learn more about the ONC 2015 Edition Health IT Certification Criteria final rule, visit: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-10-06.html

October 7, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

FAQs with Guidance on Switching EHR Vendors Now Available on CMS Website

Question: Can providers that have switched Certified Electronic Health Record (EHR) Technology vendors apply for a hardship exception to avoid the Medicare payment adjustment?

Answer: Yes, if a provider switches EHR vendors during the Program Year and is unable to demonstrate meaningful use, the provider may apply for an Extreme and/or Uncontrollable Circumstances hardship exception and if approved may be exempt from the payment adjustment.

For example, if an eligible professional (EP) switches EHR vendors in 2015 and is unable to demonstrate meaningful use in 2015, the EP can apply for an EHR Vendor Issue hardship, before the July 1, 2016 submission deadline, and be exempt from the payment adjustment in 2017.

Question: What if your product is decertified?

Answer: If your product is decertified, you can still use that product to attest if your EHR reporting period ended before the decertification occurred. If your EHR reporting period ended after the decertification occurred, you can apply for a hardship exception. If the decertification occurs after the hardship exception period has already closed for the payment adjustment year which would be applicable for your reporting period, please contact CMS Hardship Coordinator at EHRinquiries@cms.hhs.gov to apply for a hardship exception under the Extreme and/or Uncontrollable Circumstances category per CMS discretion to allow such an application.

Also, if you are a first time participant at a group practice which is switching products and the product is decertified after the hardship deadline, contact CMS at EHRinquiries@cms.hhs.gov.

September 24, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Rule to Change MU Reporting Period to 90 Days is Issued

Today, CMS issued a new proposed rule for the Medicare and Medicaid EHR Incentive Programs to align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3.

The modifications would allow providers to focus more closely on the advanced use of certified EHR technology to support health information exchange and quality improvement.

The new rule proposes a change in the reporting period for meaningful use from one year to 90 days in 2015.

Proposed Changes for EHR Incentive Programs
Together with the proposed Stage 3 notice of proposed rulemaking (NPRM) issued on March 20, 2015, the proposed rules align and merge the “stages” of meaningful use requirements.

The proposed rule changes the programs by:

  • Streamlining reporting by removing redundant, duplicative, and topped-out measures
  • Modifying patient action measures in Stage 2 objectives related to patient engagement
  • Aligning the EHR reporting period for eligible hospitals and CAHs with the full calendar year
  • Changing the EHR reporting period in 2015 to a 90-day period to accommodate modifications
April 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

New EHR Attestation Deadline for Medicare Eligible Professionals: March 20, 2015

Eligible professionals now have until 11:59 pm ET on March 20, 2015, to attest to meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 2014 reporting year.

CMS extended the deadline to allow providers extra time to submit their meaningful use data. CMS continues to urge providers to begin attesting for 2014 as soon as they can.

This extension also allows eligible professionals, who have not already used their one “switch”, to switch programs (from Medicare to Medicaid, or vice versa) for the 2014 payment year until 11:59 pm ET on March 20, 2015. After that time, eligible professionals will no longer be able to switch programs.

Medicare eligible professionals must attest to meaningful use every year to receive an incentive and avoid a payment adjustment. Providers who successfully attest for the 2014 program year will:

Note: The Medicare extension does not affect deadlines for the Medicaid EHR Incentive Program. Additionally, the EHR reporting option for PQRS has been extended until March 20, 2015. Please be on the lookout for a separate listserv with information regarding the PQRS program extension.

How to Attest
Submit your data to the Registration and Attestation System, which includes 2014 Certified EHR Technology (CEHRT) Flexibility Rule options.

Tips for speed:

  • Attest during non-peak hours, such as evenings and weekends
  • Start now to:
    • Check that your information is up to date
    • Begin entering your 2014 data

To learn more, see the Educational Resources on the CMS EHR Incentive Programs website.

February 25, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Hospitals Must Start Medicare EHR Participation in 2015 to Earn Incentives

Not participating in the Medicare EHR Incentive Program yet? 2015 is the last year for eligible hospitals to begin and still earn incentive payments.

To earn a 2015 incentive payment and avoid a 2016 payment adjustment, first-time participants should:

  • Begin their 90-day reporting period no later than April 1, 2015
  • Attest by July 1, 2015

Eligible hospitals that miss this deadline can still earn a 2015 incentive payment—and avoid the 2017 payment adjustment—if they begin their reporting period by July 1 and attest by November 30. However, they will be subject to the 2016 payment adjustment unless they apply and qualify for a hardship exception.

Hospitals that successfully attest in 2015 will also be eligible to earn a 2016 incentive if they continue to participate.

Eligible hospitals that begin participating after 2015 will not be able to earn incentive payments. They will also be subject to payment adjustments in 2016 and 2017.

Additional Resources
The EHR Incentive Programs website offers tools and resources to help eligible hospitals to successfully participate:

February 11, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

New EHR Attestation Deadline for Eligible Hospitals: December 31, 2014

I just got the following note from CMS about an extension to the EHR Attestation deadline for eligible hospitals. Here’s all the details:

CMS is extending the deadline for eligible hospitals and Critical Access Hospitals (CAHs) to attest to meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 2014 reporting year from 11:59 pm EST on November 30, 2014 to 11:59 pm EST on December 31, 2014.

This extension will allow more time for hospitals to submit their meaningful use data and receive an incentive payment for the 2014 program year, as well as avoid the 2016 Medicare payment adjustment.

CMS is also extending the deadline for eligible hospitals and CAHs that are electronically submitting clinical quality measures (CQMs) to meet that requirement of meaningful use and the Hospital Inpatient Quality Reporting (IQR) program. Hospitals now have until December 31, 2014 to submit their eCQM data via Quality Net.

Note: This extension does not impact the deadlines for the Medicaid EHR Incentive Program.

November 24, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

New Interactive Hardship Exception Tool for Eligible Professionals

Eligible professionals can now use CMS’ new interactive tool to help determine if they will avoid upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if they should apply for a hardship exception.

If an eligible professional determines that they need to apply for a hardship exception, the application must be submitted by July 1, 2014CMS will review applications to determine whether or not a hardship exception will be granted. If approved, the exception is valid for one year.

Applying for Hardship Exception
When submitting hardship exception applications, entries must include supporting documentation that proves demonstrating meaningful use presented significant hardship.

CMS has posted hardship exception applications on the EHR website for:

Please read and follow the submission instructions on the application. Note that all required supporting documentation must be included at the time of submission. Completing your application online and submitting it electronically toEHRhardship@provider-resources.com, with all required supporting documentation, will reduce the application processing time. Please do not submit hand-written applications.

Hardship Exception Tipsheets
You can also avoid payment adjustments by successfully demonstrating meaningful use prior to the payment adjustment. Tipsheets are available on the CMS website that outline when eligible professionals must demonstrate meaningful use in order to avoid the payment adjustments.

June 18, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.