You must still implement a meaningful Use certified EHR as soon as possible and demonstrate meaningful use. You have already incurred a 2% penalty on your Medicare Part B reimbursement in 2016; which will keep on increasing every subsequent year up to a maximum of 5% annual adjustment unless you start.
For the Medicare EHR incentive program you must demonstrate meaningful use every year (consecutively) or you will be subject to a payment adjustment to your Medicare reimbursement. Remember: There are no penalties in the Medicaid EHR incentive program.
The amount of incentive payment depends on the year you started your Medicare incentive program.
Those starting MU in 2013 and 2014 will not get the full incentive payments.
The rules surrounding the meaningful use electronic health record (EHR) incentive program are far from simple. And with each stage, the bar is raised. However, there are exceptions that may apply for some users who cannot meet the requirements due to circumstances out of their control.
1. There is insufficient Internet access or other infrastructure barriers, such as no broadband.
2. Newly practicing eligible professionals who have not had enough time to qualify for meaningful use may get a 2-year exception, which would give them until 2016 to demonstrate it.
3. There are unforeseen circumstances, such as a natural disaster, or other unforeseen barrier.
4. There is lack of face-to-face interaction or follow-up with patients.
5. There is lack of control over the availability of certified EHR technology for more than 50% of patient encounters (such as when practicing at multiple locations).
6. There are “2014 EHR vendor issues,” which applies if the EHR vendor did not receive 2014 certification, if the practice was unable to implement a certified EHR in time to demonstrate meaningful use, or if the practice did not have enough time to incorporate Stage 2 workflows in time to demonstrate meaningful use.
The initial deadline to apply for exceptions was April 1, 2014 for Hospitals and July 1, 2014 for EPs. However, in its most recent update (October 2014) CMS has reopened the submission period for meaningful use hardship exception applications.
The new deadline for hospitals and physicians hoping to avoid 2015 Medicare Payment adjustment is Nov 30, 2014. This new application (PDF) submission period is meant for:
a) EPs and EHs that have been unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability
b) EPs who were unable to attest by Oct. 1, 2014, and EHs that were unable to attest by July 1, 2014, using the flexibility options provided in the CMS 2014 CEHRT Flexibility Rule.