CMS: Medicare Promoting Interoperability Program Eligible Hospital and Critical Access Hospital Hardship Exception Application for the 2019

Jackie Pappalardi and Nancy Leveille in Clinical & Quality

The Centers for Medicare & 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. As required by law, downward payment adjustments must 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. If approved, the hardship exception is valid for only one payment adjustment year. Eligible Hospitals and CAHs would need to submit a new application for subsequent years and in no case may an eligible hospital or CAH be granted an exception for more than five years. 

The application for eligible hospitals and CAHs is available online via the QualityNet Secure Portal as a web-based application and can be found here. Previously registered users should already have account access, and new users can create an account by visiting QualityNet and selecting “Register”.

Medicare Promoting Interoperability Program Hardship Exception Application Details

  • You may now submit hardship applications electronically here.
  • If an electronic submission is not possible, you may verbally submit your application over the phone by calling the QualityNet Help Desk at (866) 288-8912.
  • The deadline for eligible hospitals to submit an application is September 1, 2020. Please note: This deadline has been extended from the original date of July 1, 2020 due to COVID-19.
  • The deadline for CAHs to submit an application is November 30, 2020.

For More Information

For more information about payment adjustments and hardship information, click here. For more information on the Promoting Interoperability Programs, visit the Promoting Interoperability Programs website.


Jackie Pappalardi, RN, BSN
Executive Director
518-462-4800 x16

Nancy Leveille, RN, MS
Director, Special Projects and Educational Development
518-462-4800 x20