2015 Program Year Meaningful Hardship Application Released

Last week, the Centers for Medicare & Medicaid Services released hardship applications which eligible professionals (EP) and eligible hospitals (EH) can use to avoid a penalty under Meaningful Use for the 2015 Program Year. The revised applications are required under the Patient Access and Medicare Protection Act (PAMPA), which was signed into law at the end of 2015. In the past, EPs and EHs had separate application forms, however, the new application can be used by both. Critical Access Hospitals (CAHs) have their own application (CAHs that have already submitted a form for 2015 are not required to resubmit). The new applications and instructions are to avoid a penalty in 2017 for the 2015 reporting year. Instructions for completing the applications can be found here. More information can also be found on the CMS website.

Under the new applications, CMS permits providers to file as individuals or as groups. Prior to the new law, each provider had to submit a separate application. There are several deadlines providers should be aware of:

March 15, 2016:

• Deadline for applications including only EPs
• Deadline for applications including EPs and EHs

April 1, 2016: 

• Deadline for applications including only EHs and CAHs

The law also allows providers to apply on a case-by-case basis.

CHIME is in the process of seeking clarification on the new application, particularly Section 2.2.d, “EHR Certification/Vendor Issues (CEHRT Issues).” Based on communications with CMS, it is our understanding that the description of the category where it reads, “or issues related to insufficient time to make changes to the CEHRT to meet,” is intended to capture scenarios that precluded a provider from meeting Meaningful Use as a result of the change in rules that moved the reporting period in 2015 from a full year to 90 days, rendering the ability of vendors to modify dashboards in time to comply with the last 90 days of the year, impossible.

We urge all providers who question if they will be able to successfully attest for 2015 program requirements to apply for hardship and to retain any documentation related to the filing process and justification for choosing a particular hardship category.”

Questions?

Ask your questions during the upcoming webinar:

“2015 Attestations for MU: What we know, plus filing for hardship exemptions.
February 18 (12-1pm MST)

or –

Contact CRHC’s Advisors:

• David Ginsberg, Senior Advisor, dg@coruralhealth.org
• Michelle Stuhr-Bowes, REC HIT Consultant, ms@coruralhealth.org
• Lil Sonntag, HIT Consultant, ls@coruralhealth.org