There is something about a brand-new calendar that is very empowering. With empty days just waiting to be filled, you can decide how to plan the months ahead. The first thing I like to do is to go through and mark all the special dates I already know (such as birthdays, weddings, anniversaries, etc.). Then I mark those dates that aren’t so special, but still need to be remembered (such as filing taxes).
This new year, in the world of health IT, there are several important dates to remember. Federal mandates will take center stage in 2015 as many will have to address Meaningful Use, PQRS, and consequently the value-based payment modifier. If that weren’t enough, 2015 will finally be the year in which we transition away from the decades-old ICD-9 code set to the more contemporary ICD-10 code set.
With that being said, let’s rip open our newly gifted 2015 calendars, grab our red pens, and circle some very important dates.
January 1, 2015: Start of MU and PQRS reporting periods
The first day of the year is the start of a full calendar-year reporting period for those participating in Meaningful Use (except for those in their first year). This would be the first time that an EP in stage 2 would have to participate for a full year. In 2014, CMS allowed all providers participating in MU to only report for a calendar-quarter (regardless of stage and year started).
In September, a bill called the Flexibility in Health IT Reporting (Flex-IT) Act was introduced, which would quash the Meaningful Use flexibility final rule and give attesters the option to choose any calendar-quarter for MU reporting in 2015. Although there is still a possibility that this bill could be passed, it hasn’t happened yet. Therefore, I highly suggest those in stage 2 plan to report for the full year.
The reporting period for PQRS also begins on January 1. EPs have many options for reporting PQRS. (I covered two of the more popular options here.) Unsatisfactorily reporting PQRS in 2015 will not only earn you a PQRS payment adjustment but also a value-based payment modifier adjustment in 2017—ouch!
February 27, 2015: Last day for 2014 PQRS claims submissions
For those choosing to report PQRS in 2014 via claims, this will be your last day to submit any 2014 claims to be considered.
February 28, 2015: Last day to attest for 2014 reporting period
This is the last day to attest to Meaningful Use if your reporting period occurred in 2014. If EPs did not qualify for a hardship exemption and do not attest by this date, they will face a 2% reduction in their Medicare PFS payments in 2016. Last year, CMS estimated roughly 257,000 EPs will be hit with a 1% penalty to their Medicare PFS payments beginning Jan. 5, 2015, for failing to meet Meaningful Use by Oct. 1, 2014.
Summer 2015: QRURs will be made available
For all group practices and solo EPs, CMS will make available QRURs based on data from calendar-year 2014. The QRUR will show the value-based payment scores and potential adjustments for Medicare PFS reimbursements in 2016.
July 1, 2015: Hardship exemption application deadline
As some of you may know, July 1 was the deadline for EPs to submit their hardship exemptions for MU in 2014. Although a deadline has not been set for hardship exemption applications this year, I would dare to bet it will stay the same. Approximately 55,000 EPs have been approved for hardship exemptions by CMS in the last year; around 2,000 applicants were denied, mainly because they already met the Meaningful Use measures and were simply confused by the rule. If you were granted a hardship exemption for the 2014 reporting period, it is very important to reapply in 2015 (assuming your exemption still applies). If you aren’t sure if you qualify for a hardship exemption, I suggest you read the informative blog post Dr. Ketchersid wrote on this topic.
October 1, 2015: Transition to ICD-10
The day has finally come. Despite CMS hitting the snooze button twice on this one, ICD-10 will finally make its debut. At the tail end of 2014, some organizations made one more push to get ICD-10 delayed another year—but as quickly as it made the news, it went out. The 2015 Congressional spending omnibus included October 1, 2015, as the real and actual deadline. Whether or not we see another delay in 2015 is impossible to predict, but preparing for this date is imperative.
October 3, 2015: Last day for a 90-day reporting period
This is the last day in which first-year participators of MU are able to start their reporting period. However, I would highly suggest starting way before this date.
December 31, 2015: The end of the MU and PQRS reporting periods
Finally, we made it to the end. This is the last day of the MU and PQRS reporting periods. Hopefully by this point you are all set to satisfactorily report to either or both programs. Review each measure closely and make sure you have any applicable audit materials ready to go.
As you can see, 2015 will be a big year in health IT. I can’t emphasize enough the need to plan early on. The last calendar-quarter of the year will be extremely heavy, so make sure to engage your practice and get your MU, PQRS, and ICD-10 implementation plan mastered prior to this point, and start filling in that empty calendar today.
Diana Strubler, Senior Product Analyst, Health IT Standards, joined Acumen in 2010 as an EHR trainer then quickly moved into the role of certification and health IT standards subject matter expert. She has successfully led Acumen through three certifications while also guiding our company and customers through the world of Meaningful Use, ICD-10 and PQRS.
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