Medicare Promoting Interoperability Program Hardship Exception Applications Available Now

On May 1, the Centers for Medicare & Medicaid Services (CMS) (@CMSGov) opened the Hardship Exception Application period for eligible hospitals and critical access hospitals (CAHs) that participated in the Medicare Promoting Interoperability Program in Calendar Year (CY) 2021. For the CY 2021 reporting period, CMS required that all eligible hospitals and CAHs use (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures Update criteria, or (3) a combination of the two in order to successfully meet the program requirements, as finalized in the CY 2021 Physician Fee Schedule final rule (85 FR 84818 through 84828). CMS mandates that downward payment adjustments be applied to eligible hospitals and CAHs that were not meaningful users of CEHRT and score below the 50-point minimum requirement and failed to report two self-selected calendar quarters of electronic clinical quality measures (eCQMs) data on four self-selected eCQMs.

Medicare eligible hospitals and CAHs may be exempt from Medicare penalties and avoid a downward payment adjustment if they can show that compliance with the requirement for being a meaningful certified electronic health record technology (CEHRT) user would result in a significant hardship. To be considered for an exemption, participants must complete a hardship exception application and provide proof of hardship (e.g., natural disaster, lack of internet access, etc.). If approved, the hardship exception is valid for only one payment adjustment year. Eligible hospitals and CAHs would need to submit a new application for subsequent years and no eligible hospital or CAH can be granted more than five exceptions.

Hardship Exception Application Details

  • The deadline for eligible hospitals and CAHs to submit a hardship exception application for the CY 2021 reporting period is September 1, 2022.
  • More information on the Medicare Hardship Exception Application can be found here (PDF).
  • Previously registered users should already have account access, and new users can sign up by visiting QualityNet and selecting “Register” to create a new account.
  • If an electronic submission is not possible, you may verbally submit your application over the phone by calling the Center for Clinical Standards and Quality (CCSQ) Service Center at (866) 288-8912.

For More Information

For more information on the Medicare Promoting Interoperability Program, visit the Promoting Interoperability Program website. Please see below for additional resources: