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2015 Medicare Meaningful Use Hardship Exception Applications Now Available


Because of a delay in the publication of regulations governing the Medicare meaningful use program, CMS is allowing eligible physicians and hospitals to apply for an exception under the “extreme and uncontrollable circumstances” category.

Physicians are urged to preemptively file for a 2015 hardship exception to avoid penalties in 2016. Physicians are encouraged to apply even if they are uncertain whether they will meet the program requirements this year. Doing so will not preclude physicians from receiving an incentive if they do meet meaningful use requirements, but applying can serve as a safety net in staving off a penalty.

CMA will continue to monitor this situation.


Physicians who wish to apply for an exception under the “extreme and uncontrollable circumstances” category need to do the following:

  1. Download an Application From the CMS Website
  2. Complete the Application and Check Box 2.2.d in Order to Avoid a Penalty Under the Meaningful Use Program
  3. Submit the Application

The Deadlines for Submitting Applications for Hardship Exceptions Are:

  • For Eligible Physicians: July 1, 2016
  • For Eligible Hospitals: July 1, 2016


New rules released in 2015 stated that eligible professionals must attest that they met the requirements for meaningful use stage 2 for a period of 90 consecutive days during calendar year 2015. However, the Centers for Medicare and Medicaid Services (CMS) did not publish the updated regulations for stage 2 meaningful use until October 16, 2015. As a result, eligible professionals were not informed of the revised program requirements until fewer than the 90 required days remained in the calendar year.


For more information on the electronic health record (EHR) incentive program, see the CMS tipsheet, “EHR Incentive Programs for Eligible Professionals: What You Need to Know for 2015.”

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