American College of Physicians: Internal Medicine — Doctors for Adults ®

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Practice Tips: Hardship exceptions for meaningful use

From the May ACP Internist, copyright © 2014 by the American College of Physicians

The rules surrounding the meaningful use electronic health record (EHR) incentive program are far from simple. And with each stage, the bar is raised. However, there are exceptions that may apply for some users who cannot meet the requirements due to circumstances out of their control.

At first, Stage 1 “meaningful users” receive only an incentive. But starting in January 2015, eligible professionals who did not meet meaningful use requirements in 2013 will be penalized. The payment adjustment will amount to 1% for each year (cumulative up to 5%) that the eligible professional does not demonstrate meaningful use. For practices who were (or are in the process of) implementing an EHR or whose current system is not ready, this gives very little time to use the EHR in a meaningful way.

However, in March 2014, CMS issued a rule that allows eligible professionals who did not successfully meet meaningful use in 2013 to apply for a “hardship exception.” Eligible professionals have until July 1 to apply for the exception to avoid 2015 payment adjustments based on 2013 reporting.

There are very specific circumstances that will allow clinicians to avoid the payment adjustment in 2015, and these apply only if CMS determines that they pose a significant barrier toward achieving meaningful use. Also, the exceptions apply only to clinicians who could not demonstrate meaningful use in 2013. (Forms to apply for a hardship for the 2016 payment adjustment will be available after the close of the current application period.)

Eligible professionals can apply for hardship exceptions for the following reasons:

1. There is insufficient Internet access or other infrastructure barriers, such as no broadband.

2. Newly practicing eligible professionals who have not had enough time to qualify for meaningful use may get a 2-year exception, which would give them until 2016 to demonstrate it.

3. There are unforeseen circumstances, such as a natural disaster, or other unforeseen barrier.

4. There is lack of face-to-face interaction or follow-up with patients.

5. There is lack of control over the availability of certified EHR technology for more than 50% of patient encounters (such as when practicing at multiple locations).

6. There are “2014 EHR vendor issues,” which applies if the EHR vendor did not receive 2014 certification, if the practice was unable to implement a certified EHR in time to demonstrate meaningful use, or if the practice did not have enough time to incorporate Stage 2 workflows in time to demonstrate meaningful use.

It should be noted that not every application for an exception will be approved, the exemption is for 1 year, and subsequent years will require a reapplication. Documentation, such as notice from an EHR vendor regarding the availability of a 2014 certified edition of their system, will increase the likelihood that an application will be approved.

Those who did not successfully attest for meaningful use in 2013 and who do not yet have a 2014 certified EHR system in full operation should apply for the “Vendor Issues” hardship exception before June 30, 2014.

For more information on the hardship exceptions, go online.

Margo Williams is senior associate for practice management in ACP’s Center for Practice Support, a division of ACP that encompasses the College’s primary resources for medical practices.

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