- “Eligible hospitals that do not successfully demonstrate meaningful use for an EHR reporting period associated with a payment adjustment year will receive reduced Medicare payments for that year,” clarified the federal agency in a list serv. “The payment adjustments began on October 1, 2014 for eligible hospitals. Eligible hospitals that only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments.”
The federal agency specified eligible hospitals that are not meaningful EHR users will be subject to payment adjustments starting on October 1, 2017 for fiscal year (FY) 2018.
“This payment adjustment is applied as a reduction to the applicable percentage increase to the Inpatient Prospective Payment System (IPPS) payment rate, thus reducing the update to the IPPS standardized amount for these hospitals.”
While payment adjustments may apply to some eligible hospitals unsuccessful in meeting program requirements, CMS noted over 96 percent of hospitals are meaningful users.
CMS also offered providers information about the CMS exception process.
“Eligible hospitals may apply for hardship exceptions to avoid the payment adjustment,” wrote CMS. “Hardship exceptions are granted on a case-by-case basis and only if CMS determines that requiring an eligible hospital to be a meaningful EHR user would result in a significant hardship.”
Exception application must be submitted by July 1 of the year prior to the applicable payment adjustment year.
CMS specified eligible hospitals may apply for hardship exceptions in any of the following categories:
- Infrastructure — Eligible hospitals must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).
- New eligible hospitals — Eligible hospitals with new CMS Certification Numbers (CCNs) that do not have the time to become meaningful EHR users can apply for an exception for one full cost reporting period.
- Unforeseen Circumstances — Examples may include a natural disaster or other unforeseeable barriers.
- EHR Vendor Issues — an eligible hospital’s EHR vendor was unable to obtain certification, or the hospital was unable to implement meaningful use due to EHR certification delays.
Finally, CMS emphasized that hospitals must demonstrate meaningful use every year in order to avoid payment adjustments.
“For example, an eligible hospital that demonstrates meaningful use for the first time in 2013 will avoid the payment adjustment in FY 2015, but will need to demonstrate meaningful use again in 2015 in order to avoid the payment adjustment in FY 2017,” stated the federal agency.