EH Meaningful Use Payment Adjustments and Hardship Exception

As the reporting period start date deadlines are drawing near for Eligible Hospitals (EH), and vendors are still working to get their EHR’s certified and rolled out to their customers, a big question on everyone’s minds is ‘what happens if I can’t attest in 2014?’. Eligible Hospitals must start their 90-day reporting period by July 1, 2014 in order to attest in 2014, so what options do EH’s have if they can’t meet this deadline?

First, let’s look at who Payment Adjustments affect and when these adjustments begin. The adjustments will affect Medicare EH’s as well as EH’s that bill Medicare and can participate in either the Medicare or Medicaid EHR Incentive Programs. If you are eligible for both the Medicare and Medicaid programs, you must demonstrate meaningful use in order to avoid the payment adjustment – receiving a payment for adopt/implement/upgrade (AIU) under the Medicaid EHR program does not make you exempt from payment adjustments.

Adjustments will be applied at the beginning of the 2015 fiscal year for EH’s (October 1, 2014). Hospital adjustments are based on the Inpatient Prospective Payment System (IPPS) – to read more about EH adjustments, visit the EH and CAH Hardship Exception Tipsheet. EH’s must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

So, how does CMS determine who the 2015 adjustments apply to? In order to avoid the adjustments, EH’s must demonstrate MU prior to the 2015 fiscal year. This means they have either attested to MU successfully in the 2013 reporting year or the 2014 reporting year.

What if your vendor does not deliver software to you in time to attest in 2014? In this case you can apply for a Hardship Exception based on the reason of ‘2014 Vendor Issues’.

If you are an EH who planned to attest for the first time in 2014 (new participant) and your vendor will not meet the deadline for you to attest in 2014, the deadline to file for hardship exception to avoid the 2015 payment adjustment has passed. These forms had to be submitted to CMS by April 1, 2014.

If you are an EH who attested to MU in the 2013 reporting year, you will not be subjected to the 2015 payment adjustment. But if your vendor is not able to deliver a 2014 certified solution before the attestation deadline, you can apply for a hardship exception for the 2016 payment adjustment. To apply, use the eligible hospital hardship exception for 2016. These forms must be submitted to CMS by April 1, 2015.

Contact Dynamic Health IT if you have questions about Meaningful Use or if you need assistance with your 2014 Edition Certification at 504-309-9103.