CMS has released the requirements for filing hardship exception applications for the 2015 reporting year. The good news is that CMS has reduced the amount of detailed information needed to complete the application. Additionally, CMS is allowing groups of providers to file a single hardship exception application. Hardship exception applications are due by March 15.
A hardship exception could exempt you from Medicare payment penalties in 2017 if you failed to achieve meaningful use in 2015 and you met one of the following circumstances:
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances (a natural disaster, practice closure, bankruptcy, failure of your certified EHR)
- Lack of certified EHR availability
- Lack of face-to-face interaction or follow up
There’s no hardship exemption for not knowing about the Modified Stage 2 meaningful use changes that were published in October.
While this isn’t the blanket hardship exception that many had hoped, the application requires less information than in years past, which will make the application less burdensome. Additionally, the Modified Stage 2 requirements lowered the bar on many of the more onerous measures, which should make it easier for eligible providers (EPs) to attest to meaningful use rather than applying for a hardship exception.
If you’re able to successfully attest to meaningful use for 2015, you do not need to file a hardship exception. New EPs who began submitting Medicare claims in 2015, hospital-based EPs, and EPs in five specialties unrelated to eyecare automatically receive an exemption and don’t have to file an application.
For more information, refer to the following resources:
- Payment Adjustments & Hardship Information
- Medicare EHR Hardship Exception Instructions
- Medicare EHR Hardship Exception Application (due March 15)