The day after the Super Bowl is always a tough one. According to a 2008 report, over 1.5 million workers will call in sick today, and millions more will be late. Perhaps it’s the 325 million gallons of beer Americans consumed — or the 1.3 billion chicken wings that were inhaled. Whatever the case, that’s a lot of lost productivity!
Therefore, considering the unofficial “Super Bowl Monday” holiday, I will keep today’s blog light and focus on a simple topic: important dates in 2016.
January 1, 2016: Start of MU and PQRS reporting periods
New Year’s Day marked the start of a full calendar-year reporting period for those participating in Meaningful Use (except for those in their first year). This is the first time an EP in Stage 2 has to participate for a full calendar year. In both 2014 and 2015, CMS allowed all providers participating in MU to only report for a calendar quarter.
The reporting period for PQRS also began on January 1. EPs have many options for reporting PQRS this year, and thankfully they all remain pretty similar to last year. Unsatisfactorily reporting PQRS in 2016 will not only earn you a PQRS payment adjustment but also a value-based modifier payment adjustment in 2018. Ouch.
February 26, 2016: Last day for 2015 PQRS claims submissions
If you are participating in PQRS via the claims method, this will be the last day to submit any 2015 claims.
February 29, 2016: Last day to attest for 2015 and last day to register with a PHA for 2016
It’s leap day! It’s also the last day to attest for the 2015 MU reporting period in order to avoid a 3% reduction in 2017. If this date applies to you, then you deserve an award (considering CMS has made it much easier to take a hardship in 2015)!
Providers who are not in their first year of Meaningful Use and are planning to attest to any of the three measures within the Public Health Reporting objective, February 29 is the last day to register intent with a public health agency or specialized registry.
Providers who are in their first year of Meaningful Use can attest to any 90-day reporting period, so the deadline to register intent will vary based on the start of the reporting period. If you’ve already registered successfully in the past, you do not need to register again.
March 15, 2016: Last day to submit hardship application for expedited approval
Thanks to the Patient Access and Medicare Protection Act, CMS released a new streamlined hardship application that reduces the amount of information providers must submit to apply for an exception. In order to receive an expedited hardship waiver, providers must submit their hardship applications by March 15.
For more information on how to file for “expedited approval,” check out Dr. Ketchersid’s blog post.
Summer 2016: QRURs will be made available
For all group practices and solo EPs, CMS will make available QRURs based on data from calendar year 2015. The QRUR will show the value-based payment scores and potential adjustments for Medicare PFS reimbursements in 2017.
July 1, 2016: Hardship exception application deadline
If you missed the March 15 deadline to file a hardship, it’s not too late. July 1 will be the last day to officially submit a hardship application for 2015 – but it won’t be as easy as the application that was due on March 15. Any hardship application submitted after March 15 will be reviewed on a case-by-case basis and will require more documentation. If you aren’t sure if you qualify for a hardship exception, I suggest you read the great blog post that Dr. Ketchersid wrote on this topic.
October 1, 2016: Last day for new MU participants to attest to avoid 2017 payment adjustment
If you are new to MU this year, October 1 is the last day you can attest to avoid a payment adjust in 2017. In order to avoid the 2018 payment adjustment, you won’t need to attest until Feb 28, 2017. New participants who successfully demonstrate meaningful use in 2016 and attest by October 1 will avoid the payment adjustment in 2017.
October 3, 2016: Last day for a 90-day reporting period
This is the last day in which first-year participants of MU are able to start their reporting period. I would highly suggest starting way before this date to avoid the 2017 payment adjustment (as explained above).
December 31, 2016: 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.
Other things to watch for in 2016
Thankfully this year is pretty similar to previous years in terms of deadlines and programs to follow. However, you’ll still want to pay close attention to what’s happening on Capitol Hill (i.e., the reformation of MU and the implementation of MIPS). With a lot of unknowns still floating around, it’s hard to say what else could change or be added to the dates above. As always, we will be following legislation closely and will keep you informed!
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.