CMS has issued FAQ #14357 clarifying that applying for a hardship exemption from the 2017 meaningful use payment penalty will not preclude physicians from receiving the incentive if they successfully attest to meaningful use in 2015. In essence, the hardship exemption will act as a safety net.
[EHR Incentive Program] If I submit a hardship exception application by the March 15, 2016 deadline, does that mean that I cannot attest for the 2015 EHR reporting period and possibly receive an incentive pay?
No. Submission of a hardship exception application does not prevent a provider from attesting and receiving an incentive payment if meaningful use requirements are met.
Attestation for the 2015 EHR reporting periods is currently open. We urge providers to try to attest by the March 11, 2016 attestation deadline. If they successfully attest, they will avoid the payment adjustment in 2017 and may also be eligible to receive an EHR Incentive payment.
However, if a provider cannot attest for a 2015 reporting period or believes their attestation may be unsuccessful, the provider can apply for a hardship exception to avoid the payment adjustment in 2017. The application will not prevent a provider from earning an incentive if their attestation is in fact successful. The deadline to submit a hardship exception application is March 15, 2016 for eligible professionals and April 1, 2016 for eligible hospitals.
Released: February 19, 2016, 2:26 pm
| Updated: February 23, 2016, 1:10 pm