March 2016 Client Newsletter
Meaningful Use Hardship Exception Application
As sent to CMB clients February 10, on January 22nd, the Centers for Medicare and Medicaid Services (CMS) announced that they created a new online system for submitting an application for a hardship exemption from the EHR Meaningful Use Incentive Program (MU). This new system also makes it easier to fill out an application by allowing providers to select from certain categories rather than submitting a general request for an exemption that is judged on a case-by-case basis.
You may already be aware that last week the American Medical Association sent out an announcement encouraging all physicians - even those who believe they've met the MU requirements - to apply for the hardship exception.
This new opportunity is occurring due to legislation passed by Congress at the end of 2015:
S. 2425, the Patient Access and Medicare Protection Act. This new system is temporary and only meant to aid providers for the 2015 reporting year. Providers have until March 15, 2016 to attest that they meaningfully used EHR technology in 2015 or face a one percent downward payment adjustment in 2017 unless they request and are granted a hardship exemption.
Due to the new process, it is expected that most requests for the hardship exception will be approved so it is strongly recommended that qualified health professionals apply for the exemption.
The new "streamlined" system reduces the amount of information providers need to submit in their applications for a hardship exemption. Additionally, provider groups can submit a single application for the entire group. The categories providers can select from include:
- Insufficient Internet Activity
- Extreme and Uncontrollable Circumstances
- Practice or Hospital Closure
- Severe Financial Distress
- EHR Certification/Vendor Issues
- Lack of Control over the availability of CEHRT
- Lack of Face-to-Face Patient Interaction
When Rich reviewed the above list, he was concerned about the categories and decided to reach out to the HBMA Washington contact. The response was that the above terms are not defined. There is no specific requirement for "financial hardship," "disaster," etc. He was told by CMS that it will likely take longer for the application to be completed than it will be for CMS to approve it. AMA's recommendation above is noteworthy and parallels these comments.
Note that the program operates on a two-year look-back period, meaning that physicians who are granted an exception for the 2015 program will avoid a financial penalty for 2017.
To apply, click the Hardship Exception Application link:
Instructions and Application links are midway down the page.
Please be sure to notify Rich if you apply and send us a copy of the approved exemption in case we need it in 2017.
Any questions, feel free to call Rich at 888-633-2457.
PQRS - 2016
A couple of reminders - if you are doing PQRS for 2016 and need a Registry that will support your efforts, Cape Medical Billing may be able to help. As a member of HBMA, one of our professional associations, we have access to a strong Registry provider for a discounted rate of less than $210 per provider. If interested, let Rich know and we will forward the details.
Sending an email with patient information
Just a reminder that an unencrypted email cannot be sent with any patient information in it. That would be a HIPAA Security breach. You can use our fax or your CMB Share Point account to transmit such information.
Ambulance ALS Transports
United Healthcare Community Plan (UHCC)
Effective 2/1/16 - UHCC is requiring that their runs also follow the reimbursement approach for ALS the same as Medicare and Medicaid. Thus, for those clients billing direct to a hospital for ALS Medicare/Medicaid, be sure to include UHCC.
If CMB is handling, we will be handling the same as Medicare and Medicaid when the patient has ALS services.