CMS Announces Re-Opening of Submission Period for Hardship Exception

CMS announced today that they were re-opening the period in which those wishing to apply for a Meaningful Use “Hardship Exemption” due to inability to implement a 2014 edition of Certified Electronic Health Record Technology (CEHRT). The original deadline to apply has long passed; it was July 1, 2014. The new deadline will be 11:59 PM EST on November 30, 2014. If a provider qualifies as noted below and is granted the exemption, they could avoid a 2015 Medicare payment adjustment. However, the hardship exemption is limited.

Today’s announcement by CMS makes the point that “these are the only circumstances that will be considered for this reopened hardship exception …”. The two relevant circumstances are as follows:

  • The provider is attesting for 2014 and is unable to meet the flexibility options provided earlier. (A “decision tree” chart on the “CMS 2014 CEHRT Flexibility Rule” can be linked to here.)
  • The provider has experienced delays in fully implementing 2014 edition CEHRT due to not having 2014 CEHRT availability.

The original 2014 CEHRT hardship exemption guidance can be found at this link.

The new application for the “re-opened” hardship exception can be downloaded at this link; it is important to note the words “due 11/30/2014” in the application title to ensure the proper form is used.

For additional assistance on this or other reimbursement issues, please feel free to contact us at 800-399-6565 or visit our website at

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