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CMS Releases Hardship Exception Guidance for Stage 2 Meaningful Use

March 14, 2014—The Centers for Medicare and Medicaid Services (CMS) released additional guidance for Medicare-eligible hospitals and eligible professionals (EPs) on certified EHR technology (CEHRT) hardship exceptions under the Medicare EHR incentive program, meaningful use (MU). Unless an exception applies, Medicare EPs who are not meaningful users in 2013 will be subject to a payment adjustment beginning Jan. 1, 2015; for Medicare eligible hospitals, the payment adjustment would begin Oct. 1, 2014. These exceptions were included in the final Stage 2 Meaningful Use Regulation.

Under the revisions, hospitals and EPs who are not able to implement CEHRT in 2014 may apply for a hardship exception for the 2016 payment adjustment due to “2014 Vendor Issues.” Also, if a hospital or EP intends to demonstrate MU for the first time in 2014, they may also apply for a hardship exception to the 2015 payment adjustment. 

Hospitals have until April 1, 2014 to submit a hardship exemption application. EPs have until July 1, 2014 to submit an application. CMS is currently only accepting hardship exception applications for the 2015 payment adjustment year.

CMS has posted more information and a revised tipsheet for hospitals, as well as more information and a revised tipsheet for EPs on its website.


Evan Collins, MHA
Specialist, Clinical Operations and Policy
Telephone: 202-828-0552


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806