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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.

Last Day for Medicare Eligible Professionals to Register for 2013 EHR Incentive

Today is the last day to register for the 2013 EHR incentive money. If you haven’t done so already, you’ll want to go and do that now. Unlike ICD-10, I don’t see this being delayed.

Here’s an email from CMS with details of the deadline:

If you are an eligible professional, today is the last day you can register and attest to demonstrating meaningful use for the 2013 Medicare EHR Incentive Program. You must successfully attest by 11:59 p.m. Eastern Daylight Time, to receive an incentive payment for your 2013 participation.

CMS extended the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program to allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year.

Medicaid Eligible Professionals
Eligible professionals participating in the Medicaid EHR Incentive Program need to refer to their state deadlines for attestation information.

Payment Adjustments
Payment adjustments for eligible professionals will be applied beginning January 1, 2015, to Medicare participants that have not successfully demonstrated meaningful use. For more information, visit the payment adjustment tipsheet for eligible professionals.

You must attest to demonstrating meaningful use every year to receive an incentive and avoid a payment adjustment.

If you are only eligible to participate in the Medicaid EHR Incentive Program, you are not subject to payment adjustments.

Resources

Plan Ahead
Review important dates for the EHR Incentive Programs and all CMS eHealth programs using this Interactive Timeline.

March 31, 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.

Timeline and Details of Medicare EHR Penalties

Eligible professionals (EPs) participating in the Medicare EHR Incentive Program may be subject to payment adjustments beginning on January 1, 2015. CMS will determine the payment adjustment based on meaningful use data submitted prior to the 2015 calendar year. EPs must demonstrate meaningful use prior to 2015 to avoid payment adjustments.

Determine how your EHR Incentive Program participation start year will affect the 2015 payment adjustments:

If you began in 2011 or 2012…
If you first demonstrated meaningful use in 2011 or 2012, you must demonstrate meaningful use for a full year in 2013 to avoid the payment adjustment in 2015.

If you began in 2013…
If you first demonstrate meaningful use in 2013, you must demonstrate meaningful use for a 90-day reporting period in 2013 to avoid the payment adjustment in 2015.

If you plan to begin in 2014…
If you first demonstrate meaningful use in 2014, you must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid the payment adjustment in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, to avoid the payment adjustment.

Avoiding Payment Adjustments in the Future
You must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid.

If you are only eligible to participate in the Medicaid EHR Incentive Program, you are not subject to these payment adjustments.

February 3, 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.

How to Avoid Medicaid EHR Penalties (Payment Adjustments)

I got an email from CMS which does a great job summarizing the coming EHR Medicaid penalties (they prefer to call them Medicaid payment adjustments). I thought many of my readers would find the information useful.

Medicare eligible professionals (EPs) who do not demonstrate meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program may be subject to payment adjustments beginning on January 1, 2015. Because payment adjustments are mandated to begin on the first day of the 2015 calendar year, CMS will determine the payment adjustments based on meaningful use data submitted prior to the 2015 calendar year.

These payment adjustments will be applied to the Medicare physician fee schedule amount for covered professional services furnished by the EP in 2015. EPs who do not demonstrate meaningful use is subsequent years will be subject to increased payment adjustments in 2016 and beyond.

EPs that began participation in 2011 or 2012
EPs who first demonstrated meaningful use in 2011 or 2012 must demonstrate meaningful use for a full year in 2013 to avoid payment adjustments in 2015.

EPs that begin participation this year (2013)         
EPs who first demonstrate meaningful use in 2013 must demonstrate meaningful use for a 90-day reporting period in 2013 to avoid payment adjustments in 2015.

EPs that plan to begin participation in 2014 
EPs who first demonstrate meaningful use in 2014 must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid payment adjustments in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, in order to avoid the payment adjustments.

Note: EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

Eligibility
Only EPs that are eligible for the Medicare EHR Incentive Program are subject to payment adjustments. Use CMS’ Eligibility Widget to determine for which programs you are eligible. Medicaid EPs who can only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments.

Resources
For more information on EP payment adjustments, view the Payment Adjustments and Hardship Exceptions Tipsheet for EPs and the How Payment Adjustments Affect Providers Tipsheet.

May 30, 2013 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.