The Centers for Medicare & Medicaid Services (CMS) would like to announce that the Medicare Promoting Interoperability Program calendar year (CY) 2023 Hardship Exception application period is now open as of May 1, 2024.
Application Submission Details
The deadline to submit a Hardship Exception application for the CY 2023 reporting period is August 31, 2024 for eligible hospitals and November 30, 2024 for critical access hospitals (CAHs).
Medicare eligible hospitals and CAHs may submit their Hardship Exception application using the Hospital Quality Reporting (HQR) system. Previously registered users should already have account access, and new users can sign up by 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) Help Desk at (866) 288-8912.
About Hardship Exceptions
For the CY 2023 electronic health record (EHR) reporting period, CMS required that all eligible hospitals and CAHs use the 2015 Edition Cures Update certified electronic health record technology (CEHRT) criteria in order to successfully meet the program requirements. The Social Security Act mandates that downward payment adjustments be applied to eligible hospitals and CAHs that were not meaningful users of CEHRT, which could include receiving a score below the 60-point minimum scoring requirement, and/or failing to report a full year’s worth of data on three self-selected electronic clinical quality measures (eCQMs), plus the Safe Use of Opioids Concurrent Prescribing eCQM.
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 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.
For More Information
More information on the Medicare Hardship Exception application can be found here (PDF). For more information on the Medicare Promoting Interoperability Program, visit the Promoting Interoperability Program website.