How to Avoid Meaningful Use Penalties
We are encouraging providers to consider making application for the
“2017 Medicare EHR Incentive Program Payment Adjustment Hardship Exception”
Before March 15, 2016
and here’s why…….
On January 29, 2016, CMS posted a Payment Adjustment Hardship Exception FAQ discussing how providers may/should apply for a hardship exception from Medicare reimbursement adjustments for 2017 based upon the late release of the “Final Rule”.
We are urging all providers to make application now. The deadline for submission is March 15, 2016.
If you are absolutely, positively 100% certain that you have successfully attested for 2015 and there is 0% chance that an audit at a later date won’t find any deficiencies (and some of them could be subjective), then you don’t need to worry about Medicare Reimbursement Adjustment. What could possibly go wrong? After all, you’re dealing with the Federal Government.
Here are just some of the trip-wires that can affect your ability to successfully prove (and retain) Meaningful Use for 2015:
- Your stats might be a bit short of the mark.
- You might not get to attesting in time.
- You attest in time, and it’s successful, but you are audited prior to receiving the CEHRT incentive payment….. and the auditors feel that your security risk analysis comes up short, or you’re just a little shy on any one of the myriad parameters.
- You attest in time, and it’s successfully, and you’ve actually received your payment. “I’m home free, you’re thinking.” Not so fast. Within the past month, we have had providers ask for help on CEHRT audits from attestations as old as 2011 and 2012. I’m not sure what the statute of limitations is, and it’s unclear how this could retroactively effect your reimbursement rate, but it’s definitely worth thinking about.
So, IF you successfully attest for 2015, and IF you are not subsequently audited (either before OR after receiving an incentive payment), and IF you successfully pass the EHR audit, then you don’t need to worry and your 2017 reimbursements will not be affected and you will NOT need to file for a hardship exception. That’s a lot of IF’s and possible things that can go bump in the night. If any one of these items affect your incentive payment, then YOU WILL receive a 1% payment adjustment for 2017. Seems that the prudent man….. or woman…… would want to make sure that they protect the few hard-earned dollars that Medicare allocates toward patient care.
Convinced? Good.
Filing the hardship exception application is easy, fast and no supporting documentation is required. Payment Adjustment Hardship Exception FAQ should answer many of your questions about this process.
And here’s the link to Instructions: Medicare EHR Hardship Exception Instructions
And the link to the Application: Medicare EHR Hardship Exception Application You will need to complete section “2.2.d EHR Certification/Vendor Issues (CEHRT Issues)” on Page 3.
< < < DEADLINE FOR FILING: MARCH 15, 2016 > > >
Please remember that filing for the EHR Hardship Exception does NOT affect any incentive payment
you may receive under the CEHRT Incentive program.
But it WILL affect future Medicare reimbursements for services.
Jan Kench