The Centers for Medicare & Medicaid Services (CMS) requires all hospitals to meaningfully use certified electronic health record technology (CEHRT) as part of the Medicare Promoting Interoperability Program. Eligible hospitals and critical access hospitals that are unable to meet the requirements for meaningful use of CEHRT face potential Medicare payment adjustment penalties.

Hospitals seeking to avoid those penalties may request an exception on the basis that complying with the Promoting Interoperability Program requirements would result in significant hardship for the hospital. Any such hardship must be based on either on insufficient availability of information or extreme and uncontrollable circumstances, such as a natural disaster, hospital closure, bankruptcy or debt restructuring, or electronic health record (EHR) certification or vendor issue.   

Eligible hospitals seeking a hardship exception must submit a hardship application, along with any supporting documentation, through CMS’ online portal by September 1, 2020. Critical access hospitals must submit their hardship applications by November 30, 2020. If approved, the hardship exception is valid for one payment year. Additional information regarding payment adjustments and hardship information can be found on the CMS website.

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