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Payment Adjustments & Hardship Information

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 (EHR) Technology under the Medicare EHR Incentive Program.

If a health care provider is eligible to participate in the Medicare EHR Incentive Program, they must demonstrate meaningful use each year to avoid a payment adjustment. Health care providers who are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, must demonstrate meaningful use each year to avoid the Medicare payment adjustment regardless of whether they participate in the Medicare or Medicaid EHR incentive program.

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 EHR Incentive Program are not subject to payment adjustments.

EPs, 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 Information

2018 Eligible Professional (EP) Hardship Form

The deadline for Eligible Professionals (EPs) to submit Hardship forms for the 2018 payment adjustment, based on the 2016 EHR reporting period was July 01, 2017.


2019 Eligible Hospital Hardship Form

The deadline for Eligible Hospitals to submit Hardship forms for the 2019 payment adjustment, based on the 2017 EHR reporting period is July 01, 2018.

2019 Eligible Hospital Hardship Application


2017 Critical Access Hospitals (CAHs) Hardship Form

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.

2017 CAH Hardship Application


Payment Adjustment Fact Sheets

Eligible Professional (EP) Payment Adjustment information can be found here.

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.

EP, CAH and Eligible Hospital Reconsideration

If an EP, eligible hospital or CAH receives notification that they are subject to a Medicare EHR 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 Eligible Professional and Critical Access Hospital applications was February 19th, 2018.

Eligible Professional

The deadline for Eligible Professionals (EPs) to submit Reconsideration forms for payment adjustment year 2018 was February 19, 2018. 


Critical Access Hospital

The deadline for Critical Access Hospitals (CAHs) to submit Reconsideration forms for payment adjustment year 2018 was February 19, 2018.

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