Deadline for Meaningful Use Hardship Extended

By eHealth Specialist Ann Guilmette

The Centers for Medicare & Medicaid Services (CMS) has extended the deadline by which providers can submit streamlined Meaningful Use hardship exception applications for Program Year 2015 to July 1st, 2016 (formerly 3/15/16). CMS is extending the deadline so providers have sufficient time to submit applications to avoid potential adjustments to their Medicare payments in 2017.

Eligible professionals, eligible hospitals and critical access hospitals (CAH) may be exempt from payment adjustments if they can show that demonstrating meaningful use would result in a significant hardship. If approved, the hardship exception is valid for one payment year only. A new application must be submitted if the hardship continues for the following payment year. In no case may a provider be granted an exception for more than five years.

The streamlined hardship applications reduce the amount of information that eligible professionals (EPs), eligible hospitals, and CAHs must submit to apply for an exception. The new applications and instructions for a hardship exception from the Medicare Electronic Health Records Incentive Program 2017 payment adjustment are available below.

*Please note: CAHs should use the form specific for the CAH hardship exceptions related to an EHR reporting period in 2015. CAHs that have already submitted a form for 2015 are not required to resubmit.

Links to Hardship Application and Instructions:

Security Risk Analysis Documentation Requirement for Program Year 2015 Attestations

The Vermont Medical Assistance Provider Incentive Repository (MAPIR)  will become available on May 20th, 2016, to manage EHR incentive payment applications. As you prepare to submit Payment Year 2015 provider applications for the Medicaid EHR Incentive Program, please note that you will be required to upload a copy of a security risk analysis to the provider’s attestation. Please review the CMS 2015 Specification Sheet for this Meaningful Use requirement. CMS has also published the following with more guidance:

Objective 1: Protect Patient Health Information (ePHI). Can the security risk analysis or review take place outside the EHR reporting period?

Answer: Yes, it is acceptable for the security risk analysis to be conducted outside the EHR reporting period; however, the analysis must be conducted for the certified EHR technology used during the EHR reporting period and the analysis or review must be conducted on an annual basis and include the full EHR reporting period.