Scoring, Payment Adjustment, and Hardship Information

Performance-based Scoring Methodology

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.

Medicare Hardship Exception Information

Eligible hospitals and CAHs may be exempt from a 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 have completed and submitted a hardship exception application by September 1, 2021. 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 five years.

Medicare Hardship Exception Application

  • The hardship exception application period for performance year 2020 closed on September 1, 2021
  • 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 hardship reconsideration applications for eligible hospitals and CAHs will close December 3, 2021.

Additional Resources

Page Last Modified:
12/01/2021 08:00 PM