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February 2016
CLINICAL PRACTICE MANAGEMENT
Avoid 2017 Medicare EHR Incentive Program Payment Penalties
The Medicare Electronic Health Records (EHR) Incentive Program requires eligible professionals and hospitals to demonstrate meaningful use of certified EHR technology by attesting to a set of objectives and measures determined by the Center for Medicare and Medicaid Services (CMS). Clinicians who do not comply with the program are subject to negative payment adjustments, which began in 2015. 
 
For clinicians who cannot satisfactorily meet the EHR Incentive Program’s requirements due to hardships that are out of their control, CMS makes available a streamlined application they may submit to claim hardships that hinder satisfactory reporting and avoid payment adjustments.. The new hardship exception application also allows group practices with multiple providers to submit a single application. The hardship exception application has the following hardship categories that clinicians may claim to avoid payment,
  • Insufficient Internet Connectivity
  • Extreme and Uncontrollable Circumstances
  • Disaster,
  • Practice or Hospital Closure
  • Severe Financial Distress
  • EHR Certification/Vendor Issues
  • Lack of Control over the Availability of Certified EHR Technology
  • Lack of Face-to-Face Patient Interaction
Furthermore, in agreement with the American Medical Association’s (AMA) recommendations (PDF), IDSA is encouraging all physicians who are eligible to participate for the Medicare EHR Incentive Program to apply for hardship exemption under the “EHR Certification/Vendor Issues” (option 2.2.d in the application). Due to the delay in publication of Medicare EHR Incentive Program regulations, this category will broadly apply to all physicians and CMS has stated that they will refrain from auditing physicians who apply under option 2.2d – EHR Certification/Vendor Issues.  
 
The deadline for hardship exception applications is March 15, 2016. 
Please review the Hardship Exception Application Instructions (PDF) for full details on approved circumstances of significant hardship, providers who need not apply, and how to fill out the Hardship Exception Application (PDF).  
 


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