mu hardship exceptions
DESCRIPTION
In this webinar, we explore the topic of Meaningful Use (MU) hardship exceptions. This should be of great interest to practices who are unable to attest for MU Stage 2 through no fault of their own. Here you'll find background on the exceptions, the categories CMS uses to determine valid hardships, and basic instructions on how to apply.TRANSCRIPT
MU Hardship Excep0ons Wednesday, April 2, 2014
Disclaimer: Nothing that we are sharing is intended as legally binding or prescrip7ve advice. This presenta7on is a synthesis of publically available informa7on and best prac7ces.
Agenda
• Introduc-ons • Background • Payment Adjustments • What is Hardship Excep-on? • Impact of Excep-on • MU Hardship Deadline • Who Qualifies? • What’s next? • Q&A
Background
• Part of ARRA (American Recovery and Reinvestment Act) congress mandates adjustments applied to EP’s (eligible professionals) who did not meet MU
• Payment adjustments applied star-ng Jan 1, 2015
• Medicaid only providers are not included in adjustments
• EP’s who did not meet MU in beginning of 2014
• Payment adjustment is applied to the Medicare physician fee schedule
• Payment adjustment is 1% per year
• Payment adjustment is cumula-ve for every year the provider does not meet MU
• Payment adjustments begin January 1, 2015
Payment Adjustments
Adjustment Impact
• If 75% of EP’s meet MU by 2018 the adjustment caps at 3%
• If less than 75% of EP’s meet MU by 2018 the adjustment can reach as high as 5%
Adjustment Impact Table
> 75% EP’s MU < 75 EP’s MU
2015 99% 99%
2016 98% 98%
2017 97% 97%
2018 97% 96%
2019 97% 95%
2020 97% 95%
EP’s A[ested Prior to 2015
• EP’s that first a[ested in 2011 and 2012 must demonstrate MU for a full calendar year in 2013
• A\er a[es-ng EP’s must maintain MU compliance every calendar year therea\er to avoid adjustments
• October 1, 2014 last day to a[est to avoid adjustment in 2015
What is the Hardship Excep-on
• An excep-on that allows EP’s to avoid the payment adjustments star-ng in 2015
• Only given under circumstances outlined by CMS • CMS determines if circumstances pose barrier to
achieving MU • Provider must show that demonstra-ng MU would result
in significant hardship • Applica-on must be submi[ed in addi-on to proof of the
hardship • Hardship will last for one year • Hardship excep-on can be u-lized a maximum of 5 years
Do I Qualify?
• EP’s a[es-ng for first -me in 2014 but unable to implement CEHRT
• Payment adjustments only apply to Medicare Incen-ve program
• Adjustments do not apply for Medicaid
Eligible Providers – Infrastructure – New eligible professionals
– Unforeseen circumstances
– 2014 EHR vendor issues
– Pa-ent interac-on – Prac-ce at mul-ple loca-ons
Eligible Hospitals
– Infrastructure – New eligible professionals
– Unforeseen circumstances
– 2014 EHR vendor issues
Reasons for Excep-on
Infrastructure
• EP’s must demonstrate they are without sufficient internet access
• EP’s must demonstrate barriers faced to obtaining infrastructure – Lack of broadband
New Eligible Professionals
• New EP’s granted a 2 year limited excep-on • New EP’s that start prac-cing in 2015 would be granted excep-on un-l 2017
Unforeseen Circumstances
• Natural disaster • Other unforeseen circumstances
Prac-ce at Mul-ple Loca-ons
– Lack of control over availability of CEHRT of more than 50% pa-ent encounters
Pa-ent Interac-on
• Lack of face to face interac-on with pa-ents • Lack of follow up needs with pa-ents
EHR Vendor Issues
• Vendor unable to obtain CEHRT cer-fica-on 2014
• EP unable to implement MU due to cer-fica-on delays from vendor
Exemp-on
• Special-es classified in the Medicare Provider enrollment Chain and Ownership System (PECOS) with specialty codes – Diagnos-c Radiology – Nuclear Medicine – Interven-onal Radiology – Anesthesiology – Pathology
Exemp-on
• EP’s enrolling in a new Medicare program • Hospital based EP’s for 2012 or 2013 – If 90% or more of covered professional services in and inpa-ent facility or emergency department
Applica-on
• Applica-ons must be completed and signed electronically by July 1, 2014
• Along with applica-on proof of hardship is also required • If applica-on is approved it is valid for 1 payment year only • If EP is claiming excep-on for the following year a new
applica-ons must be submi[ed • Access the applica-on on the CMS website for addi-onal
informa-on at: h[p://www.cms.gov/Regula-ons-‐and-‐Guidance/Legisla-on/EHRIncen-vePrograms/Downloads/HardshipExcep-on_EP_Applica-on.pdf
Mul-ple NPI’s Applica-on
• A physician that has mul-ple NPI’s will need to complete a separate applica-on
• Mul-ple NPI’s applica-on can be accessed at: h[p://www.cms.gov/Regula-ons-‐and-‐Guidance/Legisla-on/EHRIncen-vePrograms/Downloads/HardshipExcep-on_EP_Applica-on_Mul-pleNPIs.pdf
