• EPs who participate in the Medicare EHR Incentive Program.
• EPs who can participate in either the Medicare or Medicaid EHR Incentive Programs.
• These payment adjustments will be applied beginning on January 1, 2015, for Medicare EPs.

• Medicaid EPs who can only participate in the Medicaid EHR Incentive Program and do not bill Medicare.

How much are the payment adjustments and how are they applied?

The payment adjustment will be applied to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during the year (including the fee schedule amount for purposes of determining a payment based on the fee schedule amount).

The payment adjustment is 1% per year and is cumulative for every year that an EP is not a meaningful user. Depending on the total number of Medicare EPs who are meaningful users under the EHR Incentive Programs after 2018, the maximum cumulative payment adjustment can reach as high as 5%.

• Infrastructure - EPs must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).
• New EPs - Newly practicing EPs who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments. Thus EPs who begin practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating meaningful use in calendar year 2016 to avoid payment adjustments in 2017.
• Unforeseen Circumstances - Examples may include a natural disaster or other unforeseeable barrier.
• Patient Interaction - Lack of face-to-face or telemedicine interaction with patients; Lack of follow-up need with patients.
• Practice at Multiple Locations - Lack of control over availability of CEHRT for more than 50% of patient encounters