Meaningful Use Stage 2: Transition of Care Measure – Hardship Exemption Option for Providers

ASCRS has heard from many members who are attesting to Stage 2 Meaningful Use and having difficulty meeting the Health Information Exchange objective, which requires providers to use CERHT to create a summary of care record and electronically transmit the summary to a receiving provider for more than 10% of transitions of care and referrals. Our members have reported this measure is difficult to meet because many providers they refer to are not using an EHR system and cannot receive electronic summaries of care. 

ASCRS contacted CMS about this issue and argued that this measure unfairly penalizes providers who have EHR systems but are prevented from meeting Meaningful Use because other providers have chosen not to adopt EHR systems or participate in the program.  

CMS informed ASCRS that providers who are unable to meet the Health Information Exchange objective due to the actions of other providers may claim the Unforeseen Circumstances Hardship Exemption to avoid the Meaningful Use penalty for 2015. 

ASCRS recommends providers both attest for Meaningful Use 2015 and fill out the hardship exemption for 2015, if they are unable to meet this measure.

ASCRS has advocated to CMS that this is still an unfair measure for providers who are scheduled to receive incentive money in 2015 because their only option is to claim a hardship exemption and forego their incentive money. We will continue advocating for changes to this measure.

For more information on the Stage 2 modifications requirements, view ASCRS’ guide for Meaningful Use 2015-2017. If you have any questions, please contact Ashley McGlone, manager of regulatory affairs, at 703-591-2220.