The Medicare Promoting Interoperability Program Hardship Exception Application for Eligible Hospitals and CAHs is Now Available

The Medicare Promoting Interoperability Program Hardship Exception Application for Eligible Hospitals and CAHs is Now Available

On May 1, the Centers for Medicare & Medicaid Services (CMS) opened the Hardship Exception application period for eligible hospitals and critical access hospitals (CAHs) that participated in the Medicare Promoting Interoperability Program in calendar year (CY) 2022.

For the CY 2022 electronic health record (EHR) reporting period, CMS required that all eligible hospitals and CAHs use (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures Update criteria, or (3) a combination of the two in order to successfully meet the program requirements, as finalized in the CY 2021 Physician Fee Schedule final rule (85 FR 84818 through 84828). CMS mandates that downward payment adjustments be applied to eligible hospitals and CAHs that were not meaningful users of CEHRT and score below the 60-point minimum requirement and failed to report three self-selected calendar quarters of electronic clinical quality measures (eCQMs) data on four self-selected eCQMs.

Medicare eligible hospitals and CAHs may be exempt from Medicare penalties and avoid a downward payment adjustment if they can show that compliance with the requirement for being a meaningful certified electronic health record technology (CEHRT) user would result in a significant hardship. To be considered for an exemption, participants must complete a Hardship Exception application and provide proof of hardship (e.g., natural disaster, lack of internet access, etc.). If approved, the Hardship Exception is valid for only one payment adjustment year. Eligible hospitals and CAHs would need to submit a new application for subsequent years and no eligible hospital or CAH can be granted more than five exceptions.

Application Details

The deadline to submit a Hardship Exception application for the CY 2022 reporting period is July 31, 2023 for eligible hospitals and September 30, 2023 for CAHs. More information on the Medicare Hardship Exception application can be found here (PDF).

Medicare eligible hospitals and CAHs may submit their Hardship Exception application using the Hospital Quality Reporting (HQR) system. Previously registered users should already have account access, and new users can sign up by selecting “Register” to create a new account.

If an electronic submission is not possible, you may verbally submit your application over the phone by calling the Center for Clinical Standards and Quality (CCSQ) Service Center at (866) 288-8912.

For More Information

For more information on the Medicare Promoting Interoperability Program, visit the Promoting Interoperability Program website.

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