Thursday, March 13, 2014

The Meaningful Use Stage 2 Hardship Application

Many people have emailed me about the Meaningful Use Stage 2 Hardship application for hospitals and eligible professionals.

The most common question is - if I apply for hardship, what happens to my incentives and penalties?  Here is my understanding:

Put simply, if you want to get an incentive you have to do MU.  For *Medicare* providers once they start their first payment year their yearly clock for incentives keeps ticking regardless of whether they do MU or not.  So miss a year = no incentive. The following year would be whatever the next available incentive is scheduled to be, NOT the one that was just missed.   So there is no such thing as deferred incentives.

Applying for hardship means not doing MU, which means no incentive for that year (which means gone forever). If a provider is favorably granted the hardship then they would not be subject to the penalty to which that hardship is applicable.  In the case of 2014 performance, it is the basis for the 2016 penalty.

So to make it real.

If a (non-first-time) provider applies for a hardship for 2014 performance, presumably that means they cannot demonstrate MU, which means no 2014 incentive, but when granted the hardship it means they avoid being penalized in 2016.

If a provider does MU in 2014, they get the 2014 incentive AND avoid the 2016 penalty.


Anonymous said...

Thanks, John! Clear and to the point - as always.

Anonymous said...

Timely topic John. One question following your logic a bit further would be:
What if a hospital applies for hardship because all things look like they will not be able to attest, but they get things in order by July 1 and do actually make their dates.
1.) is this allowed?
2.) Wouldn't folks then view the hardship as an insurance item to at least get out of the 2016 penalties if things continue along a bad path for them this next few months?

John Halamka said...

That seems reasonable to me - as long as the reporting period begins July 1 and attestation is done on time, MU stimulus should be available, regardless of the hardship exemption filed