Scoring, Payment Adjustment, and Hardship Information

Performance-based Scoring Methodology

If a health care provider is eligible to participate in the Medicare Promoting Interoperability Program, they must successfully demonstrate meaningful use of their certified electronic health record technology (CEHRT) each year to avoid a downward payment adjustment. In the Fiscal Year 2019 Inpatient Prospective Payment System final rule, the Centers for Medicare & Medicaid Services (CMS) finalized a new performance-based scoring methodology for eligible hospitals and critical access hospitals (CAHs) that submit an attestation to CMS under the Medicare Promoting Interoperability Program. 

Medicare Promoting Interoperability Program Scoring

Eligible hospitals and CAHs are required to report certain measures from the Medicare Promoting Interoperability Program’s four objectives, with performance-based scoring occurring at the individual measure-level. Each measure is scored based on the eligible hospital or CAH’s performance for that measure, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require a Yes/No attestation. 

The scores for each of the individual measures are added together to calculate the total score of up to 100 possible points for each eligible hospital or CAH. A total score of 50 points or more will satisfy the requirement to report on the objectives and measures of meaningful use, which is one of the requirements for an eligible hospital or CAH to be considered a meaningful EHR user and avoid a downward payment adjustment. Eligible hospitals or CAHs scoring below 50 points will not be considered meaningful EHR users.

Review the 2020 (PDF)  Promoting Interoperability Scoring Methodology fact sheet for more information.

Medicare Payment Adjustment Fact Sheets

  • Medicare eligible hospital and CAH payment adjustment and hardship exception information can be found here (PDF).
  • Medicare payment adjustments and hardship exceptions table from 2019 through 2020 can be found here (PDF).

Medicare Hardship Exception Information

Eligible hospitals and CAHs may be exempted from the Medicare downward payment adjustment if they can show that compliance with the requirement for being a meaningful EHR user would result in a significant hardship. To be considered for an exception (to avoid a downward payment adjustment), eligible hospitals and CAHs must complete and submit a Hardship Exception Application. 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 in no case may an eligible hospital or CAH be granted an exception for more than 5 years.

Medicare Hardship Exception Application

  • The deadlines for eligible hospitals and CAHs to submit hardship forms for the 2021 (eligible hospital) / 2019 (CAH) payment adjustment year are:
    • Eligible Hospitals: The period for eligible hospitals to submit a Hardship Exception Applications closed on September 1, 2020.
    • CAHs: The period for CAHs to submit a Hardship Exception Application closed on November 30, 2020.
  • More information on the Medicare Hardship Exception Application can be found here (PDF).
  • For questions regarding the Hardship Exception Application please contact the QualityNet help desk for assistance at or 1-866-288-8912.

Medicare Promoting Interoperability Program Hardship Reconsideration Information

Eligible hospitals and CAHs may submit a request for reconsideration if CMS determines that the eligible hospital or CAH did not meet the Medicare Promoting Interoperability Program requirements for the annual payment determination. If an eligible hospital or CAH feels that they are subject to the payment adjustment for Medicare in error, they must complete and submit a Hardship Reconsideration Application.

  • The deadline for eligible hospitals to submit a hardship reconsideration application for the 2021 payment adjustment year is December 14, 2020. The eligible hospital hardship reconsideration application can be found here (PDF).
  • CMS will notify CAHs in late 2020 if they are subject to a downward payment adjustment for their 2019 performance. CAHs will have until January 2021 to submit reconsideration applications.
  • For questions regarding the hardship reconsideration application please contact the QualityNet help desk for assistance at or 1-866-288-8912.
Page Last Modified:
12/03/2020 09:43 AM