Provider Notice issued 03/12/14

Notice of Medicare Deadlines - Payment Adjustments and Hardship Exceptions

In the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated that payment adjustments should be applied to Medicare eligible professionals (pdf) (EPs) who are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program. Payment adjustments are applied by the Medicare program only; Medicaid will not apply payment adjustments.  The Illinois Department of Healthcare and Family services is sending this notice to make providers aware of potential adjustments that may be imposed by Medicare.

If a provider is eligible to participate in the Medicare EHR Incentive Program, they must demonstrate meaningful use in either the Medicare EHR Incentive Program (pdf) or in the Medicaid EHR Incentive Program (pdf), to avoid a payment adjustment. Medicaid providers who are only eligible to participate in the Medicaid EHR Incentive Program are not subject to these payment adjustments.

EPs who successfully demonstrated meaningful use in 2013 will not be subject to payment adjustments in 2015. EPs who first demonstrate meaningful use in 2014 must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid payment adjustments in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, in order to avoid the payment adjustments. These payment adjustments will be applied beginning on January 1, 2015 for Medicare eligible professionals. EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

Hardship Exceptions

Eligible professionals may be exempt from payment adjustments if they can show that demonstrating meaningful use would result in a significant hardship. To be considered for an exception, an eligible professional must complete a Hardship Exception application along with proof of the hardship. To avoid payment adjustments for 2015, the Hardship Exception application must be submitted no later than midnight EST on July 1, 2014. If approved, the hardship exception is valid for one payment year only. A new application must be submitted if the hardship continues for the following payment year. In no case may a provider be granted an exception for more than five years.

For more information, please visit the Centers for Medicare and Medicaid Services (CMS) payment adjustments and hardship exceptions web page.

For enrollment information, please visit the Federal EHR Incentive Program web page, Illinois' EHR Incentive Program web page, or contact the EHR Team at (877)782-5565 (select option 8).

EHR Provider Incentive Payment program questions and concerns can also be submitted by email to hfs.ehrincentive@illinois.gov, or by contacting one of the Regional Extension Centers at (855) 684-3571.

Theresa A. Eagleson, Administrator

Division of Medical Programs