Scoring, Payment Adjustment, and Hardship Information
Beginning in 2019, all eligible professionals (EPs), eligible hospitals, dual-eligible hospitals, and critical access hospitals (CAHs) are required to use 2015 edition certified electronic health record technology (CEHRT) to meet the requirements of the Promoting Interoperability (PI) Programs. Note that the requirements for eligible hospitals, dual-eligible hospitals, and CAHs that submit an attestation to CMS under the Medicare PI Program were updated in the 2019 IPPS final rule.
In 2019, all Medicaid eligible hospitals and EPs must adhere to the requirements of their state’s Medicaid Promoting Interoperability Program and attest directly to their state. Visit the 2019 Promoting Interoperability Medicaid page for more 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 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 CAHs that submit an attestation to CMS under the Medicare Promoting Interoperability Program beginning with the EHR reporting period in calendar year 2019.
Medicare Promoting Interoperability Program Score
Beginning in 2019, eligible hospitals and CAHs will be required to report certain measures from the 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 Promoting Interoperability 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.
For more information on the Promoting Interoperability score and methodology please review this fact sheet.
Medicaid Promoting Interoperability Program
In the final rule (83 FR 41668), States are not required to adopt the new scoring methodology and measures. States have the option to adopt the new scoring methodology and measures for their Medicaid Promoting Interoperability Programs. Any State that wishes to exercise this option must submit a change to its State Medicaid HIT Plan for CMS approval. If a State chooses not to submit such a change, or if the change is not approved, the new scoring methodology and measures will not apply.
For more information on the Medicaid Promoting Interoperability Program, visit here.
Medicare Payment Adjustment Fact Sheets
- CAH Medicare Payment Adjustment information can be found here.
- Eligible Hospital Medicare Payment Adjustment information can be found here.
- Medicare Payment Adjustments & Hardship Exceptions Table from 2017 through 2019 can be found here.
Medicare Reconsideration Information
If an eligible hospital or CAH receives notification that they are subject to a Medicare Promoting Interoperability payment adjustment and believes there is an error, they can apply for reconsideration during the applicable application period.
Payment Adjustment Year 2017 Medicare EHR Incentive Program CAH Reconsideration Application
- To be reconsidered for the 2017 payment adjustment, click here.
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 Forms
- 2018 Eligible Hospital Hardship Application
- The deadline for eligible hospitals to submit hardship forms for the 2020 payment adjustment years, based on the EHR reporting period in 2018, is July 1, 2019.
- 2018 CAH Hardship Application
- The deadline for CAHs to submit hardship forms for the 2018 payment adjustment, based on the EHR reporting period in 2018, is November 30, 2019.
All correspondence regarding reconsideration of eligible hospital and CAH Hardship Exceptions requests should be sent to firstname.lastname@example.org.
All correspondence regarding eligible hospital and CAH Payment Adjustment Reconsideration should be sent to email@example.com.
- Page last Modified: 03/19/2019 12:07 PM
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