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2015 Hardship Exemption

MU, CQR, PQRS, etc.

Last Post by Anonymous 1 second ago

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emaher

(@emaher)

Posts: 71

Estimable Member

Topic starter

Wondering if anyone was planning on filing for a hardship exemption for 2015.

I was initially under the impression that a hardship exemption would be granted to anyone who requests it on the basis that the final rule was released after the last possible 90-day reporting period of 2015 had started.

Reading the hardship exemption form, it doesn't look like this is the case. There is a place where you can indicate vendor issues, and I think this is the closest fit.

Posted : January 28, 2016 4:56 am

mcwilson

(@mcwilson)

Posts: 92

Estimable Member

I believe you are correct in that the section 2.2.d EHR Certification/Vendor Issues (CEHRT Issues) is the correct option if you are claiming the timing of the CMS final rule being the root cause.
Specifically this part:

"...or issues related to insufficient time to make changes to the CEHRT to meet CMS regulatory requirements for reporting in 2015."

We are claiming the 2015 hardship for this very reason.

Link to Hardship Form:

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/HardshipApplication.pdf

Posted : January 28, 2016 5:23 am

emaher

(@emaher)

Posts: 71

Estimable Member

Topic starter

Are you planning to write a narrative substantiating why you need the hardship exemption? I feel that the main reason to request one is the last minute requirement to submit data to two registries.

Posted : January 28, 2016 9:11 am

mjharunk

(@mjharunk)

Posts: 191

Reputable Member

Active engagement was clarified in an FAQ. Everyone has the option to take alternate exclusions for Objective 10. They just have to state that they weren't planning on attesting to the now defunct menu measure.

Posted : January 28, 2016 11:09 am

emaher

(@emaher)

Posts: 71

Estimable Member

Topic starter

The other sticking point for us is the summary of care (transition of care out) measure. GE's workflow is insane. I ran through the steps and it took me almost 10 minutes. I'm sure you'd get faster with practice, but still... Our physicians were not willing to use the GE solution.

We purchased the Surescripts ACM module to simplify the TOC workflow. Setup is a bear requiring you to add all of the physicians to which you refer patients to the Service Provider dictionary. This took months to complete. We didn't have time to complete setup and get the providers trained.

Posted : January 29, 2016 9:25 am

emaher

(@emaher)

Posts: 71

Estimable Member

Topic starter

I've done a little more research, and it sounds like you don't have to supply a narrative or vendor letter for requesting a hardship exemption.

See: https://engage.gehealthcare.com/docs/DOC-189444

Posted : January 29, 2016 9:39 am

emaher

(@emaher)

Posts: 71

Estimable Member

Topic starter

Does anyone know if a hardship exemption will be granted to all who request one?

Posted : February 2, 2016 3:16 am

JClarkLRGH

(@jclarklrgh)

Posts: 31

Eminent Member

@emaher My reading/interpretation of the FAQ is that they will rubber stamp any application that uses 2.2d. They will not check the documentation or even require documentation to be submitted and will simply check the reason used and approve any providers on the application.

https://questions.cms.gov/faq.php?faqId=12845&id=5005

If you call the QualityNet Help Desk they are usually pretty good in delivering a definitive answer.

Posted : February 9, 2016 8:58 am

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