February 19, 2016

Deadlines Approach for MU Participants and Certain Non Participants

For Meaningful Use program participants, the Centers for Medicare and Medicaid Services (CMS) recently extended the attestation deadline for calendar year (CY) 2015 reporting periods for the EHR Incentive Program (Meaningful Use) until 11:59PM (Eastern), March 11.

Additionally, CMS will make attestation system changes around February 21 to fix an error in which the appropriate exclusion (for “neither orders nor creates”) is not available to view or select for the first measure of EP Objective 8, “Patient Electronic Access.” All CY 2015 MU participants planning to use this particular exclusion should postpone attestation until after February 21 but before March 11.

ACR members who did not participate in MU will continue to be automatically exempted from penalties if their primary specialties are listed in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) as “diagnostic radiology” (30), “nuclear medicine” (36) or “interventional radiology” (94). As was the case last year, manual applications or actions of any kind are not required to obtain this automatically awarded hardship exception.

All other nonparticipants, specifically radiation oncologists and non-radiologists, should submit an application for a hardship exception for noncompliance in CY 2015 by March 15, 2016, to avoid associated penalties in CY 2017. Please see this website for instructions and an application form. Again, the vast majority of ACR’s members do not need to take this action per the previous paragraph.

For more information, please contact Michael Peters, ACR Director of Regulatory and Legislative Affairs, at 202-223-1670 or mpeters@acr.org.