As the Medicare and Medicaid EHR Incentive Programs amp up their requirements, many healthcare organizations are considering EHR replacement. However, switching vendors may hamper some organizations’ ability to participate in meaningful use in the short term.
To account for that, the Centers for Medicare & Medicaid Services (CMS) developed hardship exceptions. According to CMS, hardship exceptions are an exemption from payment adjustments if an organization can prove that demonstrating meaningful use would apply a considerable hardship at that time. To clear up confusion regarding EHR replacement and hardship exemptions, CMS has released the answers to two frequently asked questions.
Question: Can providers that have switched Certified Electronic Health Record (EHR) Technology vendors apply for a hardship exception to avoid the Medicare payment adjustment?
Answer: Yes, if a provider switches EHR vendors during the Program Year and is unable to demonstrate meaningful use, the provider may apply for an Extreme and/or Uncontrollable Circumstances hardship exception and if approved may be exempt from the payment adjustment.
Want to publish your own articles on DistilINFO Publications?
Send us an email, we will get in touch with you.
For example, if an eligible professional (EP) switches EHR vendors in 2015 and is unable to demonstrate meaningful use in 2015, the EP can apply for an EHR Vendor Issue hardship, before the July 1, 2016 submission deadline, and be exempt from the payment adjustment in 2017.
Question: What if your product is decertified?
Answer: If your product is decertified, you can still use that product to attest if your EHR reporting period ended before the decertification occurred. If your EHR reporting period ended after the decertification occurred, you can apply for a hardship exception. If the decertification occurs after the hardship exception period has already closed for the payment adjustment year which would be applicable for your reporting period, please contact CMS Hardship Coordinator at .(JavaScript must be enabled to view this email address) to apply for a hardship exception under the Extreme and/or Uncontrollable Circumstances category per CMS discretion to allow such an application.
The increased trend of EHR replacement is a result of Stage 3 Meaningful Use requirements,EHRIntelligence.com recently reported. This is because as CMS continues to develop more meaningful use requirements, more providers are updating their systems to meet those requirements. Providers are implementing strategies from transitioning old paper documents to EHRs, and upgrading already existing EHRs to reflect meaningful use standards.
Although hardship exceptions may be a good route for some organizations to take in ensuring replacement success in the short term, there are some important steps organizations can make to ensure success in the long term, as well. These best practices are within the healthcare facility’s control and can aid a smooth EHR transition.
First, providers should ensure that their replacement takes into account data security to prevent security breach. Second, providers should bear in mind that facility culture and a mindset of reform are essential in getting the most out of a new EHR. Third, providers should hold themselves accountable for their deadlines in order to yield a timely transition. Fourth, past failures and successes should shape the direction the EHR transition is taking. And fifth, training and expertise should go from the top down, starting with organization executives.
As EHR incentive requirements continue to evolve, as will the EHRs themselves. Thus, it is important to have effective plans, including those involved with Medicare and Medicaid and those within the control of the organization.
Date: September 24, 2015