Applying for 2015 Meaningful Use Hardship Exceptions

The deadline to apply for 2015 Meaningful Use hardship exceptions is quickly approaching on March 15, 2016. Applying, and being approved for the hardship will void EPs from the 2017 payment adjustment. 

What You Should Know About Applying for the Meaningful Use Hardship Exception

Hardship exceptions are granted only under specific circumstances that may have posed a barrier for EPs trying to achieve Meaningful Use. In order to file for an exception you must be able to explain the circumstances beyond your control and outline how those circumstances disruptedMeaningful Use Criteria your ability to meet Meaningful Use criteria. Here are some situations that could qualify you for an exception:

  • Lack of Infrastructure. For example, being located in an area without sufficient Internet access and/or you face barriers for obtaining the needed infrastructure.
  • Extreme or Uncontrollable Circumstances. This could include natural disasters, or your EHR vendor's inability to obtain certification. 
  • Patient Interactions. Lack of face to face or telemedicine interaction with patients, or lack of follow up need with patients. 
  • New Professionals. Newly practicing professionals can apply for a two year limited exception to penalties.
  • Multiple Locations. Lack of control over availability of certified EHR for more than 50% of patient encounters. 

In October of 2015, the CMS posted the Stage 2 Meaningful Use Final Rule after EPs began the presumed 90-day reporting period. This gave doctors no time to prepare to meet the requirements for 90 days since the revisions weren't provided until there were less than 90 days remaining in the year. The CMS has stated that the hardship exception of uncontrollable and extreme circumstances can be used for issues that were related to this delay and to avoid the 2017 penalty.

Applying for an exception by the deadline doesn't prevent EPs from attesting and receiving incentive payment if Meaningful Use requirements are met. So even if you've attested, it doesn't hurt to apply for exception.

To get started with your hardship application, fill out the CMS Hardship Exception Application. The CMS also has a Hardship Exception Tool that will help you determine if you can avoid upcoming payment adjustments by applying for an exception. 

Additional Resources:

CMS Hardship Exception Application
CMS Hardship Exception Tool
American Optometric Association Update
CMS FAQs

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