Scoring, Payment Adjustment, and Hardship Information

Performance-based Scoring Methodology

In the Fiscal Year (FY) 2022 Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) Final Rule, CMS made updates to its performance-based scoring methodology for eligible hospitals and critical access hospitals (CAHs) that attest to CMS under the Medicare Promoting Interoperability Program. Please see the Promoting Interoperability 2022 Program Requirements page for more information on reporting requirements for the CY 2022 reporting period.

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 105 possible points for each eligible hospital or CAH. For the CY 2022 reporting period, a total score of 60 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 60 points will not be considered meaningful EHR users and could be subject to a downward payment adjustment.

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 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 no eligible hospital or CAH can be granted more than five exceptions.

Medicare Hardship Exception Application

  • The deadline for eligible hospitals and CAHs to submit a hardship exception application related to the CY 2021 reporting period is September 1, 2022.
  • More information on the Medicare Hardship Exception Application can be found here (PDF).
  • For questions regarding the hardship exception application, please contact the CCSQ Service Center 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, they must complete and submit a hardship reconsideration application. The hardship reconsideration applications for eligible hospitals and CAHs will close on December 2, 2022.

Additional Resources

Page Last Modified:
11/17/2022 02:06 PM