MU Hardship Exceptions
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Transcript of MU Hardship Exceptions
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