Meaningful Use Exemption Process Critical Details

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Meaningful Use Exemption Process Critical Details

TL;DR

  • The Meaningful Use exemption application process is streamlined and easier to complete
  • The MU exemption deadline for Eligible Providers (EPs) or providers with both EPs and Eligible Hospitals (EHs) is 11:59PM ET on March 15, 2016
  • The MU exemption deadline for Eligible Hospitals is 11:59PM ET on April 1, 2016

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On January 22, 2016, the CMS unveiled the MU exemption application process.

The Patient Access and Medicare Protection Act

Recently we talked about the Patient Access and Medicare Protection Act, a law which allows some leeway in Meaningful Use reporting deadlines. If you missed this piece of legislation amidst the storm of things that come out of the Hill, here’s a brief summary:

  • Eligible hospitals and eligible physicians who find it impossible to comply with the modified Stage 2 rule released into the final 90-day reporting period of 2015 to apply under the ‘unforeseen circumstances’ category
  • Enables the Centers for Medicare & Medicaid Services (CMS) to grant hardships not just on a case-by-case basis, but also to ‘categories’ with the deadline of March 15, 2016 for EPs and April 1, 2016 for EHs, after which time CMS would still have the case-by-case authority to grant hardship exemptions until July 1, 2016

Basically, the CMS can grant your practice exemption if you provide valid reasons. With the new information on the Meaningful Use exemption process, we can see that it is streamlined. Let’s take a closer look.

The Meaningful Use Exemption Application Process

Simply go to the CMS’ website and retrieve the application; it’s recommended that you do it electronically. As stated by their press release, groups of providers may apply for Meaningful Use exemption on a single application. The hardship exception categories are the same as those applicable for the individual provider application.

The Ways to Demonstrate Significant Hardship Providing Meaningful Use

The ways you can apply for exemption:

  • Insufficient Internet Connectivity: if you live or have lived in an area without sufficient Internet access, and could not achieve meaningful use
  • Extreme and Uncontrollable Circumstances: disaster, practice closure, financial distress, and/or EHR Certification/Vendor issues all qualify for hardship exemption.
  • Lack of control over certified EHR technology availability (for EPs only): the EP(s) must attest to a lack of control over the availability of certified EHR technology in 1 or more practice locations where more than 50 percent of the patient encounters occurred.
  • Lack of face to face patient interaction (for EPs only): there must be an almost complete lack of face-to-face patient interaction and follow up. Furthermore, that this lack of interaction is not a part the normal scope of your practice

Providers Who Are Already Exempt and Do Not Need to File for MU Exemption

An important caveat: new eligible providers do not need to apply for Meaningful Use exemption, as they are already exempt. Those who do need to apply are:

New Hospitals

If you are a new eligible hospital AND obtained or will obtain a new CMS Certification Number (CCN) between 10/01/2014 and 9/30/2016, you do not need to submit this application. You will be granted a hardship exception and are automatically exempt from the 2017 payment adjustment based on the data in Medicare Provider Enrollment, Chain and Ownership System (PECOS).

Critical Access Hospitals (CAHs)

If you are a CAH, you should apply here.

Eligible Professionals (EPs)

If you are an EP in the following categories you do not need to submit this application:

  • New EPs – The “New EP” determination is based on when an EP begins to submit Medicare claims. For example, an EP who begins to submit claims to Medicare in 2015 would receive an exception to the payment adjustment in Calendar Years (CYs) 2016 and 2017, but would need to begin demonstrating meaningful use in CY 2016 to avoid the payment adjustment in CY 2018.
  • Specialties – If an EP is classified in the Medicare Provider Enrollment, Chain and
    Ownership System (PECOS) as having one of the following 5 specialty codes (Anesthesiology (05), Diagnostic Radiology (30), Interventional Radiology (94), Nuclear Medicine (36). Pathology (22) as the primary area of practice, the EP does not need to submit this form. The EP is automatically granted a hardship exception from the 2017 payment adjustment based on the designation in PECOS.
  • Hospital-Based EPs – If you are a hospital-based EP for CY 2015, you DO NOT need to submit this form to avoid the CY 2017 payment adjustment.

Final Thoughts

Remember that the deadline for Meaningful Use reporting is coming up soon (February 29th), and the application for exemption status for Eligible Providers (EPs) or providers with both EPs and Eligible Hospitals is 11:59PM ET on March 15, 2016 (EHs), and for Eligible Hospitals it is 11:59PM ET on April 1, 2016.

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