In this webinar, we explore the topic of Meaningful Use (MU) hardship exceptions. This should be of great interest to practices who are unable to attest for MU Stage 2 through no fault of their own. Here you'll find background on the exceptions, the categories CMS uses to determine valid hardships, and basic instructions on how to apply.
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MU Hardship Exceptions
1. MU
Hardship
Excep0ons
Wednesday,
April
2,
2014
Disclaimer:
Nothing
that
we
are
sharing
is
intended
as
legally
binding
or
prescrip7ve
advice.
This
presenta7on
is
a
synthesis
of
publically
available
informa7on
and
best
prac7ces.
2. Agenda
• Introduc-ons
• Background
• Payment
Adjustments
• What
is
Hardship
Excep-on?
• Impact
of
Excep-on
• MU
Hardship
Deadline
• Who
Qualifies?
• What’s
next?
• Q&A
3. Background
• Part
of
ARRA
(American
Recovery
and
Reinvestment
Act)
congress
mandates
adjustments
applied
to
EP’s
(eligible
professionals)
who
did
not
meet
MU
• Payment
adjustments
applied
star-ng
Jan
1,
2015
• Medicaid
only
providers
are
not
included
in
adjustments
4. • EP’s
who
did
not
meet
MU
in
beginning
of
2014
• Payment
adjustment
is
applied
to
the
Medicare
physician
fee
schedule
• Payment
adjustment
is
1%
per
year
• Payment
adjustment
is
cumula-ve
for
every
year
the
provider
does
not
meet
MU
• Payment
adjustments
begin
January
1,
2015
Payment
Adjustments
5. Adjustment
Impact
• If
75%
of
EP’s
meet
MU
by
2018
the
adjustment
caps
at
3%
• If
less
than
75%
of
EP’s
meet
MU
by
2018
the
adjustment
can
reach
as
high
as
5%
7. EP’s
A[ested
Prior
to
2015
• EP’s
that
first
a[ested
in
2011
and
2012
must
demonstrate
MU
for
a
full
calendar
year
in
2013
• Aer
a[es-ng
EP’s
must
maintain
MU
compliance
every
calendar
year
thereaer
to
avoid
adjustments
• October
1,
2014
last
day
to
a[est
to
avoid
adjustment
in
2015
8. What
is
the
Hardship
Excep-on
• An
excep-on
that
allows
EP’s
to
avoid
the
payment
adjustments
star-ng
in
2015
• Only
given
under
circumstances
outlined
by
CMS
• CMS
determines
if
circumstances
pose
barrier
to
achieving
MU
• Provider
must
show
that
demonstra-ng
MU
would
result
in
significant
hardship
• Applica-on
must
be
submi[ed
in
addi-on
to
proof
of
the
hardship
• Hardship
will
last
for
one
year
• Hardship
excep-on
can
be
u-lized
a
maximum
of
5
years
9. Do
I
Qualify?
• EP’s
a[es-ng
for
first
-me
in
2014
but
unable
to
implement
CEHRT
• Payment
adjustments
only
apply
to
Medicare
Incen-ve
program
• Adjustments
do
not
apply
for
Medicaid
10. Eligible
Providers
– Infrastructure
– New
eligible
professionals
– Unforeseen
circumstances
– 2014
EHR
vendor
issues
– Pa-ent
interac-on
– Prac-ce
at
mul-ple
loca-ons
Eligible
Hospitals
– Infrastructure
– New
eligible
professionals
– Unforeseen
circumstances
– 2014
EHR
vendor
issues
Reasons
for
Excep-on
11. Infrastructure
• EP’s
must
demonstrate
they
are
without
sufficient
internet
access
• EP’s
must
demonstrate
barriers
faced
to
obtaining
infrastructure
– Lack
of
broadband
12. New
Eligible
Professionals
• New
EP’s
granted
a
2
year
limited
excep-on
• New
EP’s
that
start
prac-cing
in
2015
would
be
granted
excep-on
un-l
2017
14. Prac-ce
at
Mul-ple
Loca-ons
– Lack
of
control
over
availability
of
CEHRT
of
more
than
50%
pa-ent
encounters
15. Pa-ent
Interac-on
• Lack
of
face
to
face
interac-on
with
pa-ents
• Lack
of
follow
up
needs
with
pa-ents
16. EHR
Vendor
Issues
• Vendor
unable
to
obtain
CEHRT
cer-fica-on
2014
• EP
unable
to
implement
MU
due
to
cer-fica-on
delays
from
vendor
17. Exemp-on
• Special-es
classified
in
the
Medicare
Provider
enrollment
Chain
and
Ownership
System
(PECOS)
with
specialty
codes
– Diagnos-c
Radiology
– Nuclear
Medicine
– Interven-onal
Radiology
– Anesthesiology
– Pathology
18. Exemp-on
• EP’s
enrolling
in
a
new
Medicare
program
• Hospital
based
EP’s
for
2012
or
2013
– If
90%
or
more
of
covered
professional
services
in
and
inpa-ent
facility
or
emergency
department
19. Applica-on
• Applica-ons
must
be
completed
and
signed
electronically
by
July
1,
2014
• Along
with
applica-on
proof
of
hardship
is
also
required
• If
applica-on
is
approved
it
is
valid
for
1
payment
year
only
• If
EP
is
claiming
excep-on
for
the
following
year
a
new
applica-ons
must
be
submi[ed
• Access
the
applica-on
on
the
CMS
website
for
addi-onal
informa-on
at:
h[p://www.cms.gov/Regula-ons-‐and-‐Guidance/
Legisla-on/EHRIncen-vePrograms/Downloads/
HardshipExcep-on_EP_Applica-on.pdf
20. Mul-ple
NPI’s
Applica-on
• A
physician
that
has
mul-ple
NPI’s
will
need
to
complete
a
separate
applica-on
• Mul-ple
NPI’s
applica-on
can
be
accessed
at:
h[p://www.cms.gov/Regula-ons-‐and-‐Guidance/
Legisla-on/EHRIncen-vePrograms/Downloads/
HardshipExcep-on_EP_Applica-on_Mul-pleNPIs.pdf