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Reminder: Deadline to Submit a Hardship Exception Application

centers for medicare and medicaid services Medicare Promoting Interoperability Program
Eligible Hospitals Must Submit a Hardship Exception Application by August 31

On May 1, 2024, the Centers for Medicare & Medicaid Services (CMS) opened the Hardship Exception application period for eligible hospitals and critical access hospitals (CAHs) that participated in the Medicare Promoting Interoperability Program in calendar year (CY) 2023.

*Application Submission Details*  

The deadline for eligible hospitals to submit a Hardship Exception application [ https://cmsqualitysupport.servicenowservices.com/cms_hh ] for the CY 2023 reporting period is* August 31, 2024.*

"Please note that the application period for CAHs will close on November 30, 2024."

Eligible hospitals may submit their application electronically at the following website: https://cmsqualitysupport.servicenowservices.com/cms_hh. If an electronic submission is not possible, contact the CCSQ Help Desk at 1 (866) 288-8912 and a representative will assist you with a verbal application.

*About Hardship Exception*  

For CY 2023, the 2015 Edition Cures Update [ https://www.healthit.gov/topic/certification-ehrs/onc-health-it-certification-program-test-method ] certified electronic health record technology (CEHRT) criteria were required for the Medicare Promoting Interoperability Program to successfully meet the program requirements [ https://www.cms.gov/medicare/regulations-guidance/promoting-interoperability-programs/calendar-year-2023-and-2024-program-requirements ]. CMS mandates that downward payment adjustments be applied to eligible hospitals and CAHs that were not meaningful users of CEHRT and score below the 60-point minimum requirement and failed to report a full year's worth of electronic clinical quality measures (eCQMs) data on three self-selected eCQMs plus the Safe Use of Opioids Concurrent Prescribing eCQM.

Eligible hospitals and CAHs may be exempt from a Medicare downward payment adjustment if they can show that compliance with the requirement for being a meaningful EHR user would result in a significant hardship. Simply lacking CEHRT does not qualify an eligible hospital or CAH for a Hardship Exception.

To be considered for an exception "(to avoid a downward payment adjustment)", eligible hospitals and CAHs must complete and submit a Hardship Exception application [ https://cmsqualitysupport.servicenowservices.com/cms_hh ]. 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 process can be found here (PDF) [ https://www.cms.gov/files/document/2024-hardship-exception-fact-sheet.pdf ]. For more information on the Medicare Promoting Interoperability Program, visit the Promoting Interoperability Program website [ https://www.cms.gov/medicare/regulations-guidance/promoting-interoperability-programs ]. 



Centers for Medicare & Medicaid Services




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