RE: Support for H.R. 3940, the Meaningful Use Hardship Relief Act of 2015
Dear Representative Price:
On behalf of the undersigned organizations of the Alliance of Specialty Medicine, we are writing
to express our appreciation for introducing the Meaningful Use Hardship Relief Act of 2015 (H.R.
3940). The Alliance is a coalition of national medical societies representing specialty physicians
in the U.S. and is dedicated to the development of sound federal health care policy that fosters
patient access to the highest quality specialty care. Our members recognize the value of
electronic health records (EHRs) in regards to improving the quality and efficiency of care, and
we support the goal of establishing a national health information technology (HIT) infrastructure.
As you know, in order to avoid a penalty under the Meaningful Use (MU) program, providers
must attest that they met the requirements for MU 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 Modifications Rule for Stage 2 of MU until after October 1, 2015 – meaning that
by the time providers were informed of the requirements, fewer than the 90 required days
remained in the calendar year. Because the rule also includes additional requirements for
upgrading systems and changing workflows to meet the new program measures, this timeframe
poses a significant challenge for MU participants.
While CMS has acknowledged that eligible entities may apply for a hardship exception if they are
unable to attest due to the timeframe of the rule, statute requires that the exception be granted
only on a case-by-case basis. CMS expects there be a large number of hardship applications,
making it unlikely that the agency would be able to review each case individually within a
reasonable timeframe.
H.R. 3940 would authorize a blanket MU significant hardship exception for the 2015 reporting
period due to the delay in timely publication of the Stage 2 MU rule, allowing hardship
applications to be processed in a more equitable and efficient manner
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