Here are five points:
1. The two recent developments are:
• CMS launched a streamlined process for claiming a hardship exemption
• CMS Acting Administrator Andy Slavitt said that the MU program will soon be over and replaced with something new, and possibly, improved
2. Pain specialists can use the new streamlined process to apply for a hardship exception.
3. The new hardship exception process to is based on electronic health record technology certification or control issues.
4. While MU stage 3 will still be implemented in 2017-2018, the ‘something new’ Mr. Slavitt referred to was the EHR component of the Merit-Based Incentive Payment System created by the Medicare Access and CHIP Reauthorization Act of 2015.
5. While anesthesiologists are automatically exempt from stage 3, the question of whether they will also be exempt from the MIPS requirements regarding the use of EHRs remains to be seen.
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