Home > EHR, meaningful use, Medicare > Meaningful Use Significant Hardship Exception for Radiologists Clarified

Meaningful Use Significant Hardship Exception for Radiologists Clarified

Radiologists often inquire about the significant hardship exception available to certain specialists as temporary reprieve from the payment adjustments for nonparticipation in the Medicare/Medicaid EHR Incentive Program (“Meaningful Use”). The most common question—is this automatically granted, or do I need to complete some sort of action?

As a quick background, one of the available exceptions is for physicians whose primary specialty codes in the Provider Enrollment, Chain and Ownership System (PECOS) are diagnostic radiology (30), nuclear medicine (36), or interventional radiology (94) (also anesthesiology and pathology). While the Centers for Medicare and Medicaid Services (CMS) suggested in public meetings that this particular option will be automatically granted, official written guidance from the agency lacked clarification about whether or not it will be fully and truly automatic (i.e., no further manual action required by the radiologist to obtain it).

That ambiguity has been addressed. Newly revised and enhanced guidance materials from CMS state:

Specialties – If you are classified in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) as having one of the following 5 specialty codes as your primary area of practice you DO NOT need to submit this form. You will be granted a Hardship Exception and are automatically exempt from the 2015 payment adjustment based on the data in PECOS.

  • Diagnostic Radiology (30)
  • Nuclear Medicine (36)
  • Interventional Radiology (94)
  • Anesthesiology(05)
  • Pathology (22)

Therefore, if radiologists’ primary specialty code in PECOS is 30, 36, or 94 prior to the middle of this year, they will be automatically granted the exception for CY 2015 based on their PECOS data without having to fill out additional forms. Anyone planning to take advantage of this option should double-check their PECOS data before the month of July 2014 to make sure their primary specialty code is correct.

For information about other ways to avoid Meaningful Use payment adjustments, please read this article.

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Categories: EHR, meaningful use, Medicare
  1. Karen Sykes
    April 15, 2014 at 4:09 pm

    If diagnostic radiology is automatically exempt how do we go about participating in meaningful use, and if we do MU stage1 and have trouble can we still take the exemption for stage 2?

    • mpetersacr
      April 16, 2014 at 11:13 am

      The hardship exception mechanism is only a temporary reprieve from penalties for noncompliance by those who are eligible for the Medicare version of the EHR Incentive Program. The existing statute prohibits CMS from granting the exception to an individual for more than 5 total years *throughout that individual’s entire career.* So, taking the exception route for short-term penalty avoidance instead of complying and getting incentives while there are still incentives to get is not a decision that should be taken lightly. It also needs to be a localized decision based on your practice’s own situation. ACR provides MU educational resources here: http://www.acr.org/Advocacy/Regulatory-Issues/HIT-and-Mobile-Health/Meaningful-Use (see educational materials category)

      The hardship exception is unrelated to “stages” of MU. Publicly, CMS has been unclear about how prior MU participation impacts the ability of someone to obtain the PECOS specialty code-based exception. My current impression is that you get it regardless based on your PECOS data until you use up your 5 years. This opens up the problem of how to opt out of getting it awarded to you if you were MU compliant anyway (so you don’t use up your 5 exception years). *Note that there are also various other hardship exceptions available that involve manual applications for prior participants.*

  1. May 28, 2014 at 4:43 pm
  2. June 24, 2014 at 7:47 am
  3. September 25, 2014 at 3:19 pm
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