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Elizabeth Arend

Quality Improvement Advisor

October 1 Deadline to Attest for Medicare EHR

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Mark your calendars: all eligible professionals (EPs) who are first time participants in the Medicare electronic health records (EHR) incentive program must attest by October 1, 2017 to avoid a negative payment adjustment in 2018.  EPs who do not successfully demonstrate meaningful use for the 2017 reporting period will receive reduced Medicare payments for that year.

October 1st is also the deadline for first time Medicare EHR Incentive Program participants to take advantage of CMS’s significant hardship exception for the Medicare EHR Incentive Program 2018 payment adjustment. The Center for Medicare and Medicaid Services (CMS) is offering this one-time exemption to allow EPs more time to work with their EHR vendors and prepare to report in the Advancing Care Information performance category (which replaces Meaningful Use) under the Merit-based Incentive Payment System (MIPS), which was implemented on January 1st.

A first-time participant EP can apply for the hardship exemption and avoid a 2018 payment penalty if:

  • The EP is a first-time participant in the EHR Incentive Program in 2017 and intends to participate in the Medicare EHR Incentive Program in 2017;
  • The EP is transitioning to MIPS for the 2017 performance period;
  • The EP intends to report on measures in the Advancing Care Information MIPS performance category in 2017

If an eligible provider meets all three criteria, s/he must submit the 2017 Eligible Professionals Transitioning to MIPS Hardship application by October 1, 2017. (Note: EPs who have previously participated in the EHR Incentive Program are not eligible for this one-time hardship exemption).

CMS may also grant hardship exemptions to EPs whose certified EHR technology (CEHRT) was decertified under ONC’s Health IT Certification Program during the 12-month period before 2018, if the EP made a good faith effort to obtain another CEHRT for the 2017 reporting period.

For more information on CMS’s payment adjustments and hardship information, click here.



On Wednesday, CMS released a statement exempting hospitals and doctors affected by Hurricanes Harvey and Irma from certain Medicare quality reporting programs without having to file an Extraordinary Circumstances Exemption request.