- The Centers for Medicare & Medicaid Services issued two important notices this week, one to assist providers with PQRS reporting and the other for providers to contest payment adjustments related to 2015 meaningful use reporting.
First, the federal agency notified eligible professionals of the upcoming deadline for contesting 2017 Medicare payment adjustments, which are the result of a failure to satisfy requirements for 2015 meaningful use reporting:
The deadline for Eligible Professionals (EPs) to submit Reconsideration forms for the 2017 payment adjustment—based on the 2015 EHR reporting period—is February 28, 2017. No applications will be accepted after the deadline.
Please visit the CMS website to find the EP Reconsideration Application. Complete this application if you received a letter from CMS that said you are subject to the 2017 Medicare EHR payment adjustment and you believe this payment adjustment is in error.
Second, CMS shared findings from a review of the 2015 performance period for EPs in the Physician Quality Reporting System (PQRS). In the notice issued Thursday, the federal agency provided two tips based on common errors found in the review:
- Qualified Clinical Data Registries (QCDRs), Data Submission Vendors and eligible professionals (EPs) reporting via the Electronic Health Record (EHR) direct mechanism who wish to satisfactorily report for both the PY2016 Physician Quality Reporting System (PQRS) and the Medicare EHR Incentive Program or submitting for PQRS only must indicate such in the QRDA I or QRDA III file* during submission using the PQRS_MU_INDIVIDUAL or PQRS_MU_GROUP codes. Vendors and EPs who utilize the MU_ONLY code will not have data in that file analyzed for the PQRS. EPs may be considered a satisfactory reporter for PQRS if they successfully reported via another PQRS mechanism.
- Qualified Clinical Data Registries (QCDRs), Data Submission Vendors and eligible professionals (EPs) reporting via the EHR direct mechanism using QRDA I or QRDA III file* format must report on all payers regardless of whether they are electronically reporting for 2016 PQRS only or PQRS and the Medicare EHR Incentive Program. In addition, at least one measure per EP must contain a Medicare Part B patient in order to fulfill PQRS reporting requirements. Failure to submit on at least one Medicare patient per EP will render that EP subject to the downward PQRS payment adjustment in 2018.
*Please note that QCDRs are only able to support QRDA III files.
Both programs required certified EHR technology in order to submit reporting data electronically. Earlier this month, CMS extended the deadline for 2016 PQRS reporting and meaningful use attestation from February 28 to March 13.
The previous year was the last for both programs which the Merit-based Incentive Payment System as part of the Quality Payment Program which MACRA implementation laid the groundwork for.