CMS Issues New CEHRT Deadlines for FY 2015

With October 1, 2014 marking the beginning of the 2015 Electronic Health Reporting (EHR) Incentive Program year, CMS has announced guidance on payment adjustments and hardship exceptions for Medicare-eligible hospitals and providers. The announcement highlights new deadlines for the application process and provides links to the adjustment and hardship exception applications.

Background

The American Recovery and Reinvestment Act of 2009 (ARRA) mandated that Medicare-eligible professionals and hospitals who are not “meaningful users” of Certified Electronic Health Record Technology (CEHRT) under the Medicare EHR Incentive Program will be subject to Medicare payment adjustments. If a provider is eligible to participate in the Medicare EHR Incentive Program, it must demonstrate meaningful use of the technology in either the Medicare EHR Incentive Program or in the Medicaid EHR Incentive Program. Medicaid providers who are only eligible to participate in the Medicaid EHR Incentive Program are not subject to the payment adjustments.

Payment Adjustment

The payment adjustments will be applied to eligible hospitals beginning on October 1, 2014, and to eligible professionals (EPs) on January 1, 2015. CMS offers a reconsideration application for Fiscal Year (FY) 2015 for eligible providers that believe the adjustment has been erroneously applied to them.

Hardship Exception

CMS extended the submission period for hardship exception applications and provided a new deadline for submission for eligible providers that do not use CEHRT and can show they would suffer hardship by using the technology. In order to avoid the FY 2015 payment adjustment, providers must submit the extension hardship application by November 30, 2014, along with proof of the hardship. If approved, the exception is valid for one payment year, and a new application will have to be submitted should the hardship continue for the following payment year. CMS stresses that no eligible providers will be granted an exception for more than five years.

Some providers, such as new providers in their first year and EPs who are 90-percent hospital-based, are automatically granted hardship exceptions for FY 2015. CMS will use Medicare data to determine which providers receive the exemption. Such providers do not need to submit the hardship application.

Further Guidance

In order to align with the EHR Incentive Programs, all eligible hospitals must have already obtained the 2014 edition certified EHR technology (2014 Edition CEHRT) to participate in 2015. Some hospitals require the certification for the entire year, while others may require it for only part of the year. CMS released Eligible Hospitals:Meeting Meaningful Use in 2015 with 2014 Edition Certified EHR Technology (CEHRT) for further guidance.