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 (CAHs) that are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program.
Eligible professionals and eligible hospitals may be exempt from payment adjustments, however, if they submit a hardship exception application showing that demonstrating meaningful use would result in a significant hardship. As well, some providers do not need to submit a hardship application as they are automatically exempted from the payment adjustment. Providers falling into one of the following categories receive an automatic pass:
- New providers to the profession in their first year (both eligible professionals and eligible hospitals).
- Eligible professionals who are hospital-based: a provider is considered hospital-based if he or she provides more than 90 percent of their covered professional services in either an inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital.
- Eligible professionals in which 90% of their claims include Place of Service 21, Place of Service 23 and certain observation services using Place of Service 22.
- Eligible professionals with certain PECOS specialties (05-Anesthesiology, 22-Pathology, 30-Diagnostic Radiology, 36-Nuclear Medicine, 94-Interventional Radiology) 6 months prior to the first day of the payment adjustments. Eligible professionals should verify that their PECOS specialty is up to date.
As you hear more about EHR Hardship Exceptions as the July 1, 2015, deadline approaches, remember that if you fall into one of the categories above, then you receive an automatic pass.
Otherwise, you may be on the hook for the payment adjustment unless you satisfied the requirements of Meaningful Use in 2014 or submit a hardship exception application by July 1. To file a hardship exception application, the circumstance must be beyond your control, and you must explicitly outline how the circumstance significantly impaired your ability to meet meaningful use. Follow these instructions for submitting a hardship exception application.
For more information, review the Centers for Medicare and Medicaid Services’ EHR Incentive Programs Payment Adjustments & Hardship Exceptions Web Page.
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