Medicare Eligible Professionals Must Apply for 2016 EHR Hardship Exception by July 1, 2015

Medicare Eligible Professionals (EPs) who wish to avoid the 2016 payment adjustment for the Medicare EHR Incentive Program must apply for a hardship exception by July 1, 2015 at 11:59 ET. The deadline for Eligible Hospitals to submit their 2016 Hardship applications was April 1, 2015.

As a result of ASA’s advocacy efforts, the Centers for Medicare & Medicaid Services (CMS) created a hardship exception for anesthesiologists, which exempts anesthesiologists with a Medicare Provider Enrollment, Chain, and Ownership System (PECOS) specialty 05-Anesthesiology from the payment penalties that began in 2015.

ASA members are encouraged to check their PECOS specialty designation to determine whether action is required. EPs do not need to submit a hardship application if they are a newly practicing EP, qualify as a hospital-based EP, or are EPs with certain PECOS specialties (05-Anesthesiology, 22-Pathology, 30-Diagnostic Radiology, 36-Nuclear Medicine, 94-Interventional Radiology).  Note that a provider is considered a hospital-based EP if he or she provides more than 90% of covered professional services in either an inpatient or emergency department of a hospital as determined by specific place of service (POS) codes 21 and 23.

For EPs who do not have PECOS specialty designation 05, applications and instructions for hardship exceptions are available on the CMS EHR Incentive Programs website. When filing a hardship exception, EPs must show proof of circumstances beyond their control and outline how those circumstances significantly impaired the EP’s ability to meet meaningful use. There may be other requirements for certain hardship exception categories. CMS will review applications received and decide whether a hardship exception will be granted.

Additional questions about the EHR Incentive Program?

ASA offers information about the program on our website. CMS and the Office of the National Coordinator for Health Information Technology (ONC) have made several reference tools available to guide you through the initial assessment stages. For a general overview of the EHR Incentive Program, including eligibility requirements, important dates and program incentives, please visit the CMS website. ONC provides information on EHRs for practices and physicians regarding the Health Information Technology certification process and questions on interoperability. 

For additional information, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected] or 202-289-2222.