Did you know first-time participants this year can avoid the 2018 Electronic Health Record (EHR) Incentive Payment adjustment with participation in the Advancing Care Information (ACI) portion in 2017?

Eligible professionals (EPs) who are first-time participants in the EHR Incentive Program have until October 1 of their first year to attest and avoid payment adjustments in the subsequent year. Those EPs who are first-time participants in 2017 have until October 1, 2017 to avoid the 2018 payment adjustment. We note that 2017 is also the first year of the Merit-Based Incentive Payment System (MIPS), which carries similar EHR reporting requirements to those of the Medicare EHR Incentive Program for EPs.

For first-time Medicare EHR Incentive Program participants in 2017, CENTERS for MEDICARE & MEDICAID SERVICES (CMS) is offering a one-time significant hardship exception for the Medicare EHR Incentive Program 2018 payment adjustment to provide EPs ample time to collaborate with their EHR vendors and adjust to the new reporting requirements in the advancing care information performance category of MIPS. CMS’ goal is to help those first-time participants successfully participate in MIPS for the 2017 program year.

A first-time participant EP may apply for this one-time significant hardship from the 2018 payment adjustment if:

  • The EP is a first-time participant in the EHR Incentive Program in CY 2017 and intends to participate in the Medicare EHR Incentive Program in CY 2017, and
  • The EP is transitioning to MIPS for the 2017 performance period, and
  • The EP intends to report on measures specified for the ACI performance category under MIPS in 2017

If an EP meets the criteria for this one-time exception to the 2018 EHR Incentive Program payment adjustment, the EP must submit the 2017 Eligible Professionals Transitioning to MIPS Hardship application no later than October 1, 2017. We note this is only available for first-time EPs in the EHR Incentive Program. If you have previously participated in the EHR Incentive Program, you are not eligible for this one-time hardship exemption.

For more details, visit: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html


Daniel Day is a Hospital and Physician Office Quality Improvement Advisor for AQAF, a partner of Qsource. He has been in the healthcare industry for over six years, working for several EHR companies as a project manager and consultant. He is currently working with physicians, assisting them with compliance needs. He also works with other advisors to reduce health disparities in Alabama.