Lack of infrastructure and unforeseen or uncontrollable circumstances are not the only criteria the Centers for Medicare and Medicaid Services will consider in granting hardship exemptions to health care providers who are struggling to comply with Stage 2 EHR meaningful use requirements. CMS has also added "2014 EHR vendor issues" as an acceptable reason.

In order to qualify, CMS' hardship exemption application form for eligible hospitals states: "During the fiscal year (2014) preceding the payment adjustment year (2015), the Hospital's EHR vendor was unable to obtain 2014 certification or the Hospital was unable to implement meaningful use due to 2014 EHR certification delays." The form emphasizes that "circumstance must be beyond the Hospital’s control and the Hospital must explicitly outline how the circumstance significantly impaired the Hospital’s ability to meet Meaningful Use."

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