FAQs with Guidance on Switching EHR Vendors Now Available on CMS Website

To keep you updated with information on the Medicare and Medicaid EHR Incentive Programs, CMS has recently added two new FAQs providing information on how to continue participation in the EHR Incentive Programs or apply for a hardship exception after switching vendors. We encourage you to stay informed by taking a few minutes to review the new information below.

Question: Can providers that have switched Certified Electronic Health Record (EHR) Technology vendors apply for a hardship exception to avoid the Medicare payment adjustment?

Answer: Yes, if a provider switches EHR vendors during the Program Year and is unable to demonstrate meaningful use, the provider may apply for an Extreme and/or Uncontrollable Circumstances hardship exception and if approved may be exempt from the payment adjustment.

For example, if an eligible professional (EP) switches EHR vendors in 2015 and is unable to demonstrate meaningful use in 2015, the EP can apply for an EHR Vendor Issue hardship, before the July 1, 2016 submission deadline, and be exempt from the payment adjustment in 2017.

Question: What if your product is decertified?

Answer: If your product is decertified, you can still use that product to attest if your EHR reporting period ended before the decertification occurred. If your EHR reporting period ended after the decertification occurred, you can apply for a hardship exception. If the decertification occurs after the hardship exception period has already closed for the payment adjustment year which would be applicable for your reporting period, please contact CMS Hardship Coordinator at EHRinquiries@cms.hhs.gov to apply for a hardship exception under the Extreme and/or Uncontrollable Circumstances category per CMS discretion to allow such an application.

Also, if you are a first time participant at a group practice which is switching products and the product is decertified after the hardship deadline, contact CMS at EHRinquiries@cms.hhs.gov.

For More Information
For more about the EHR Incentive Programs, visit the CMS EHR website.