- The hardship exception deadline for critical access hospitals (CAHs) that did not achieve meaningful use during the EHR Incentive Program 2016 reporting period closes on November 30.
CAHs looking to avoid a 2018 payment adjustment can apply for a hardship exception if they can show that demonstrating meaningful use would result in a significant hardship for their practice. CAHs must complete the hardship exception application and provide proof of the hardship to avoid the payment adjustment.
The hardship exception is valid for only one payment year, according to CMS. Providers will not be granted an exception for more than five years.
Inpatient prospective payment system hospitals that were unable to achieve meaningful use or receive a hardship exception for the 2016 reporting period can also apply for an exception through November 30.
CAHs may submit a hardship exception application if they meet criteria for a lack of infrastructure or an extreme and uncontrollable circumstances hardship exception.
The policy addressing extreme and uncontrollable circumstances has also been included in the second year of the Quality Payment Program (QPP). This was part of the CMS Patients Over Paperwork initiative to reduce unnecessary regulatory burden on providers and increase clinical efficiency. The hardship exception is aimed at assisting small practices and clinicians in the line of hurricanes Harvey, Irma, and Maria.
CAHs that have not previously participated in the EHR Incentive Program but would like to participate in 2016 have until February 28, 2017 to successfully attest to meaningful use and avoid a payment adjustment.
New CAHs that have not operated before 2016 are considered automatically exempt from the 2016 payment adjustment and do not need to apply. CAHs unsure about whether they should apply for a hardship exception to avoid a payment adjustment can consult the CMS CAH hardship exception application instructions.
CAHs historically have lagged behind other hospitals in advanced EHR use. A recent study by Julia Adler-Milstein, PhD and Jay Holmgren found CAHs are less likely than other hospitals to use EHR data for performance measurement and patient engagement.
The researchers voiced concern the disparity in EHR use signals the beginnings of a digital divide between CAHs and other hospitals.
“Hospital EHR adoption is widespread and many hospitals are using EHRs to support QI and patient engagement,” the duo wrote. “However, this is not happening across all hospitals.”