 Network News March 16, 2017 |
eCW MAQ Issue 
Health centers using eClinicalWorks recently received a message on the MAQ Dashboard which read, "customers who cannot utilize the 90 days of data on their MAQ Dashboards from October 3, 2016 - December 31, 2016, CMS has directed us to advise them to apply for an EHR Incentive Program hardship exception for program year 2016".
For physicians who see Medicare patients and bill Part B covered professional services, there will be a payment adjustment in 2018 for failure to attest in 2016. (The Hardship Exception only protects Medicare Part B covered professional services billed by physicians; since mid-levels are not eligible to participate in the Medicare EHR Incentive Program, they are also not subject to Medicare payment adjustments for failure to attest to meaningful use.) If your doctors were meeting the meaningful use requirements earlier in the year but faltered in the last quarter of 2016, you can file a 2018 Hardship Exception Application due to EHR Certification/Vendor Issues; instructions are also available. If the Hardship Exception Application is submitted to and accepted by CMS, the payment adjustments on Medicare Part B covered professional services in 2018 would be avoided. There are no Medicaid payment adjustments for skipping an attestation year.
|
Filing a Hardship Exemption
Follow the steps outlined below to complete the 2018 Hardship Exemption Application.
- Open the 2018 Hardship Exception Application.
- Complete Section 1.1 with the contact information of the person submitting the Application.
- In Section 2, checkmark the appropriate hardship.
- For the eClinicalWorks issue noted above, select 2.2.d - EHR Certification/Vendor Issues (CEHRT Issues). Enter the name of the person submitting the Application in the field between "I" and "on behalf of the provider(s) ...". This should match the first and last name noted in Section 1.1.
- In Section 3, enter the Individual NPI, Provider First Name and Provider Last Name for all providers experiencing this hardship.
- If your providers experience different hardships, we recommend submitting one Application per hardship. For example, you may have doctors experiencing the eClinicalWorks reporting issue noted above; you may also have doctors that practice part-time at your organization but see more encounters at another organization that does not have an EHR. For the first group of doctors, your hardship would be the EHR Certification/Vendor Issues. For your second set of doctors, the hardship would be Lack of Control over CEHRT Availability (2.3). One Application should be submitted for the doctors experiencing the EHR Certification/Vendor Issues and another Application should be submitted for the doctors experiencing the Lack of Control over CEHRT Availability. Each doctor should only be noted on the Application most applicable to their situation.
- Review Section 4. Checkmark the "Confirm" box. Enter the date in a MM/DD/YYYY format and the name of the individual completing the form; the name should match the information provided in Section 1.1 and Section 2.
- Preferably, submit the completed Application to ehrhardship@provider-resources.com; alternatively, you can fax the Application to 814-456-7132.
- Important: The submission deadline for a Medicare EHR Incentive Program Hardship Exception for payment adjustment year 2018 is July 1, 2017.
- Maintain supporting documentation of your hardship in your meaningful use records. For the eClinicalWorks reporting issue noted above, I recommend that you maintain:
- Report(s) from earlier reporting periods and/or supplemental documentation showing the doctor(s) meeting the MU requirements.
- Report from 10/03/2016-12/31/2016 showing doctor(s) are no longer meeting the MU requirements.
- Correspondence from eClinicalWorks such as the image displayed above. For your information, I have also attached the original "Message to our Customers" from eClinicalWorks dated January 27, 2017 which explains the specific measures which had to be recalculated and CMS' initial guidance to eClinicalWorks.
- Acknowledgment/Receipt from CMS of the 2018 Hardship Exception Application. Please note that the acknowledgment/receipt may be the only documentation that you receive for your Application from CMS.
|
