Home > EHR, meaningful use, Medicare > How to Avoid Meaningful Use Penalties (2015 Update)

How to Avoid Meaningful Use Penalties (2015 Update)

The negative payment adjustments for nonparticipation in the Medicare EHR Incentive Program (“Meaningful Use” or MU) will increase to -2% off covered professional services in calendar year (CY) 2016. Physicians who are eligible for the Medicare version of the program will have two ways to avoid the 2016 penalties:

Option 1: Compliance

  • Prior MU participants must have been a Meaningful EHR User in 2014 to avoid the 2016 penalties. If the prior MU participant was not MU-compliant in 2014, he/she must use Option 2 below.
  • Those who have never participated in MU must begin participating by July 1, 2015 and complete the attestation process by October 1, 2015 (at the latest) to avoid 2016 penalties. If the first-time participant does not meet the attestation deadline, he/she must use Option 2 below.

Option 2: Significant hardship exception
Regardless of whether or not a physician was MU compliant in the past, he/she can obtain one of several “significant hardship exceptions” to avoid 2016 penalties. CMS can grant these to physicians on an annual basis for up to 5 total years. The various available significant hardship exceptions are as follows:

  • Lacking broadband/infrastructure: The physician was located in an area without sufficient Internet access to comply for any 90-day period of time from the beginning of 2014 to July 1, 2015. Moreover, the physician must have faced insurmountable barriers to obtaining the internet connectivity. A manual application is required by July 1, 2015.
  • Newly practicing: The physician has been practicing for less than 2 years. This will be automatically given. No manual application is required.
  • Extreme and uncontrollable circumstances: a) A previous MU participant faced extreme and uncontrollable circumstances in 2014. Or, b) a physician who has never participated in MU faced extreme and uncontrollable circumstances in 2015. A manual application is required by July 1, 2015.
  • Inability to influence availability of certified EHR technology (CEHRT): The physician practiced at multiple locations, and lacked control over the availability of CEHRT at one or more locations where he/she had more than 50% of his/her patient encounters. A manual application is required by July 1, 2015.
  • Lack of face-to-face/telemedicine interaction with patients AND lack of need for follow-up: The physician can demonstrate difficulty in meeting MU on the basis of lack of face-to-face or telemedicine interaction with patients and lack of need for follow up with patients. A manual application is required by July 1, 2015.
  • Primary specialty listing in PECOS: The physician has a primary specialty listed in PECOS as radiology, anesthesiology, or pathology by July 1, 2015. For radiology, the primary specialty listing must be “diagnostic radiology” (30), “nuclear medicine” (36), or “interventional radiology” (94). No manual application is required.

The above information is subject to change. For more information about the significant hardship exceptions, please see CMS’ website.

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Categories: EHR, meaningful use, Medicare
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  1. April 11, 2015 at 10:37 am

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