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Payment Adjustments & Hardship Information

The Centers for Medicare & Medicaid Services (CMS) is renaming the EHR Incentive Programs to the Promoting Interoperability (PI) Programs to continue the agency’s focus on improving patients’ access to health information and reducing the time and cost required of providers to comply with the programs’ requirements. CMS is also in the process of finalizing updates to the programs through rulemaking. For more information, visit the landing page where CMS will publish updates and additional resources as soon as they are available. 

In the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated that payment adjustments should be applied to Medicare eligible professionals, eligible hospitals, and critical access hospitals (CAH) that are not meaningful users of certified electronic health record technology (CEHRT) under the PI Programs (formerly named the EHR Incentive Program).

If a health care provider is eligible to participate in the PI Program, they must demonstrate meaningful use each year to avoid a payment adjustment. Eligible Hospitals and CAHs who are eligible to participate in both PI Programs must demonstrate meaningful use each year to avoid the Medicare payment adjustment regardless of whether they participate in the Medicare or Medicaid PI Programs.

Hospital-based EP’s are not subject to Medicare payment adjustments (and are ineligible to receive an EHR incentive payment under either Medicare or Medicaid) and are defined as providing 90 percent or more of his or her covered professional services in sites of service identified by the codes used in the HIPAA standard transaction as an inpatient hospital or emergency room setting.

Medicaid health care providers who are only eligible to participate in the Medicaid PI Program are not subject to payment adjustments.

Payment Adjustment Fact Sheets

  • Critical Access Hospital (CAH) Payment Adjustment information can be found here.
  • Eligible Hospital Payment Adjustment information can be found here.
  • Payment Adjustments & Hardship Exceptions Table from 2017 through 2019 can be found here.

Reconsideration Information

If an eligible hospital or CAH receives notification that they are subject to a Medicare PI payment adjustment in error, based on the applicable performance year, they can apply for a reconsideration during the applicable application period. *Please note: The submission deadline for Critical Access Hospital applications was February 19th, 2018.

Hardship Exception Information

Eligible Hospitals, and CAHs may be exempt from Medicare penalties if they can show that demonstrating meaningful use would result in a significant hardship. To be considered for an exception (to avoid a payment adjustment) health care providers must complete a Hardship Exception application and provide proof of the hardship. If approved, the hardship exception is valid for only one payment year. Health care providers need to submit a new application for subsequent years and in no case may a health care provider be granted an exception for more than 5 years.

Hardship Exception Forms

  • 2019 Eligible Hospital Hardship Application
    • The deadline for Eligible Hospitals to submit Hardship forms for the 2019 payment adjustment, based on the 2017 EHR reporting period was July 01, 2018.
  • 2017 CAH Hardship Application
    • The deadline for Critical Access Hospitals (CAHs) to submit Hardship forms for the 2017 payment adjustment, based on the 2017 EHR reporting period is November 30, 2018.

All correspondence regarding appeals should be sent to EHRHardship@cms.hhs.gov.

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