2016 PQRS Deadlines
by Leigh-Ann Renz, 2.8.16 (updated per CMS announcements on both 2.10.16 + 2.11.16)
Claims-Based PQRS Reporting
2.26.16 is the deadline for claims-based PQRS reporting of 2015 data. Because the reporting is completed via QDC codes on actual claims / billing, the opportunity for this type of reporting will have passed for most practices. The 2.26 deadline is for the remaining unbilled claims with a date of service 1/1/15 - 12/31/15. Check out 2015 PQRS Claims Made Simple for more details.
EHR PQRS Reporting (QRDA I or III)
CMS just announced an extension on the submission date for 2015 QRDA data submission for the EHR reporting mechanism: 3.11.16 is now the deadline to submit 2015 EHR data via QRDA. Contact your 2014 Edition Certified EHR for details on using it to submit your reporting electronically.
Keep in mind that: not only does a provider have to be using a 2014 Edition Certified EHR, they also can ONLY report on the CQMs that the EHR vendor has certified. There are 64 CQMs that you could certify, but it is only the 9 (or whatever subset of the 64) that have been certified that qualify for the EHR QRDA I or III files for reporting.
Dual PQRS & Meaningful Use Reporting (eCQM)
Moments after this post was updated for the extended PQRS deadline, CMS announced that it is also extending the deadline for the Meaningful Use (MU) EHR incentive program as well. When dual reporting for both PQRS and MU, the provider chooses option 1 when submitting their MU attestation.
This means that they are going to submit their CQMs electronically through the portal. ("An Enterprise Identity Management (EIDM) account with the 'Submitter Role' is required for these PQRS data submission methods. Please see the EIDM System Toolkit for additional information.")
This is done at a separate time and is what the PQRS extension pertains to; however, due to the 2.11.16 CMS announcement, providers now need to submit both their MU attestation and their PQRS reporting by 3.11.16. They have until 3.11 to finish with the eCQMs.
If the provider chooses Option 2, they are only processing CQMs for a 90-day reporting period. That satisfies the MU program, but not PQRS. The provider would have to submit their PQRS information by some other means with the deadline assigned to that method.
If they report on the 9 CQMs certified by their EHR with Option 2, they can have zero performance rates. They could choose completely different CQMs to report for the PQRS program and use Claims or a Registry to report those CQMs.
Most registries have their own deadlines, as they need time to extrapolate and organize your practice data before submission; contact your registry for their exact deadline(s). The official deadlines for registries are:
QCDR XML - 3.31.16
Qualified Clinical Data Registries (QRDA III) - 3.11.16
Qualified Registries (Registry XML) - 3.31.16
The 2015 GPRO Web Interface submission period is from 1.18.16 - 3.11.16.
If the reporting requirements are not satisfactorily met, providers can expect a payment adjustment on all Medicare reimbursements in 2018 for failure to comply in 2016. This is in addition to any penalties they might receive for failure to meet Meaningful Use requirements.
Penalties are leveraged two years after the reporting period. Starting 1.1.16, Medicare payment adjustments will begin for both group practices and individuals who did not satisfactorily report quality data to CMS in 2014.
Site Maintenance / Possible Downtimes
Submission ends at 8:00 p.m. Eastern Time (ET) on the deadline dates listed above. "An Enterprise Identity Management (EIDM) account with the 'Submitter Role' is required for these PQRS data submission methods. Please see the EIDM System Toolkit for additional information."
Please note that maintenance is currently scheduled for the following timeframes:
• 2/26/2016 at 8:00 p.m. ET – 2/29/2016 at 6:00 a.m. ET
• 3/11/2016 at 8:00 p.m. ET – 3/14/2016 at 6:00 a.m. ET
• 3/16/2016 at 8:00 p.m. ET – 3/21/2016 at 6:00 a.m. ET
The Physician and Other Health Care Professionals Quality Reporting Portal (Portal) may be unavailable during these times.
> CMS PQRS ListServ email announcement: 2.10.16