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Meaningful Use Exemption Release

Published Tuesday, January 26, 2016
by Kelsey Reichert

On Friday January 22, 2016, CMS published information on their new approach for providers and hospitals to seek a hardship exception to eliminate penalties created through the federal MU program. These changes are a result of recent Medicare legislation – the Patient Access and Medicare Protection Act (PAMPA), Pub. L. No. 114-115.

According to the news release, “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.”

This means that CMS will allow groups of doctors and other medical professionals to use a single application for exemptions to a penalty for failing to meet federal rules on EHR, using the new exemption forms now posted on the website, available here. The new form allows providers to apply for an exemption under different categories instead of using a case-by-case basis. The categories are as follows:

  1. Insufficient Internet Connectivity
  2. Disaster
  3. Practice or Hospital Closure
  4. Severe Financial Distress
  5. EHR Certification/Vendor Issues (CHERT Issues)
  6. Lack of Control over CHERT Availability (EPs only)
  7. Lack of Face to Face Interaction or Follow UP (EPs only)

Please note it is our assumption number 5 above, “EHR Certification/Vendor Issues,” is the “catch all” exception we have previously discussed, and would be used when others do not apply.

Also, EPs, eligible hospitals, and CAHs must submit their application for the 2017 EHR Incentive Program Payment Adjustment according to the timeline established in PAMPA:

  • Eligible Professionals & a combined application with EPs and Hospitals: March 15, 2016
  • Eligible Hospitals (when not combined with EPs) & CAHs: April 1, 2016

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