Now Available: Medicare Promoting Interoperability Hardship Exception Applications for Hospitals and CAHs

May 15, 2019


The Centers for Medicare and Medicaid Services (CMS) requires that all eligible hospitals and critical access hospitals (CAHs) use 2015 edition certified electronic health record technology (CEHRT) to meet the requirements of the Promoting Interoperability Programs. CMS mandates downward payment adjustments be applied to eligible hospitals and CAHs that are not meaningful users of CEHRT.

Eligible hospitals and CAHs may be exempt from Medicare penalties if they can show that compliance with the requirement for being a meaningful EHR user would result in a significant hardship. To be considered for an exemption, eligible hospitals and CAHs must complete a hardship exception application and provide proof of hardship.

The application for eligible hospitals and CAHs is now available online and can be found here. The application deadline for eligible hospitals is July 1, 2019. The application deadline for CAHs is November 30, 2019.


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459 or

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