Wednesday, February 10, 2016

Hospitals Must Start Medicare EHR Participation in 2015 to Earn Incentives

Not participating in the Medicare Electronic Health Record (EHR) Incentive Program yet? 2015 is the last year for eligible hospitals to begin and still earn incentive payments. To earn a 2015 incentive payment and avoid a 2016 payment adjustment, first-time participants should:

• Begin their 90-day reporting period no later than April 1, 2015
• Attest by July 1, 2015

Eligible hospitals that miss this deadline can still earn a 2015 incentive payment and avoid the 2017 payment adjustment if they begin their reporting period by July 1 and attest by November 30. However, they will be subject to the 2016 payment adjustment unless they apply and qualify for a hardship exception.

• Hospitals that successfully attest in 2015 will also be eligible to earn a 2016 incentive if they continue to participate.
•Eligible hospitals that begin participating after 2015 will not be able to earn incentive payments. They will also be subject to payment adjustments in 2016 and 2017.

Payment Adjustments & Hardship Exceptions

Payment Adjustments
If a provider is eligible to participate in the Medicare EHR Incentive Program, they must demonstrate meaningful use in either the Medicare EHR Incentive Program or in the Medicaid EHR Incentive Program, to avoid a payment adjustment. Medicaid providers who are only eligible to participate in the Medicaid EHR Incentive Program are not subject to these payment adjustments.

Medicare hospitals began to receive payment adjustments on October 1, 2014, and Medicare eligible professionals will begin to receive payment adjustments on January 1, 2015.

Hardship Exceptions to Avoid Medicare Payment Adjustments
Eligible professionals and eligible hospitals may be exempt from payment adjustments if they can show that demonstrating meaningful use would result in a significant hardship.  To be considered for an exception, an eligible professional or eligible hospital must complete a Hardship Exception application along with proof of the hardship.  If approved, the hardship exception is valid for 1 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 5 years.
Eligible professionals can use the Hardship Exception Tool to determine if they will avoid the upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if they should apply for a hardship exception.

Eligible Professional (EP) Hardship Exception Application
2015 Eligible Professional Hardship application deadline was July 1, 2014
2016 Eligible Professional Hardship application will be available soon.
Eligible Hospitals Hardship Exception Application
2015 Eligible Hospital Hardship application deadline was April 1, 2014
2016 Eligible Hospital Hardship application will be available soon.

Not All Providers Apply for Hardship Exceptions

Some providers will automatically be granted a hardship exception. CMS will use Medicare data on these providers to determine their hardship exception.

The following providers do not need to submit a hardship application:
New providers to the profession in their first year (both eligible professionals and eligible hospitals)
Eligible professionals who are hospital-based: a provider is considered hospital-based if he or she provides more than 90% of their covered professional services in either an inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital*
Eligible professionals in which 90% of their claims include Place of Service 21, Place of Service 23 and certain observation services using Place of Service 22.

Eligible professionals with certain PECOS specialties (05-Anesthesiology, 22-Pathology, 30-Diagnostic Radiology, 36-Nuclear Medicine, 94-Interventional Radiology) 6 months prior to the first day of the payment adjustments. Eligible professionals should verify that their PECOS specialty is up to date.

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