Important Medicare deadlines on March 20

Physicians face March 20, 2015, submission deadlines in order to qualify for Medicare meaningful use and Physician Quality Reporting System (PQRS) incentive payments for the 2014 reporting year, and avoid payment reductions under both programs in 2016.

Eligible professionals (EPs)¹ who have not attested to their meaningful use under the Medicare Electronic Health Record (EHR) Incentive Program for the 2014 program year have until 11:59 p.m. ET on March 20, 2015, to do so. The previous deadline was February 28, 2015, which the Centers for Medicare & Medicaid Services (CMS) recently extended to allow additional time for EPs to submit their 2014 meaningful use data.

Successful attestation for 2014 is required in order for an EP (or the EP’s employer or other practice entity taking reassignment from the EP) to receive an incentive payment for the 2014 program year and avoid a negative Medicare payment adjustment in 2016. In some cases, EPs have been granted hardship exceptions upon application. CMS has stated its expectation that more than 50 percent of EPs may be subject to penalties for not satisfying meaningful use requirements.

This extended deadline does not apply to attestation under the Medicaid EHR Incentive Program. However, EPs who have not previously switched between the Medicare and Medicaid EHR Incentive Programs have until March 20 to make the switch.

March 20, 2015, is also the extended deadline for the submission of PQRS information through either a certified EHR technology vendor or a qualified clinical data registry. However, the PQRS deadline is four hours earlier than the meaningful use deadline, at 8:00 p.m. ET as opposed to 11:59 p.m. EPs and group practices that meet PQRS participation or reporting requirements for 2014 can be eligible for PQRS incentive payments and avoid PQRS payment reductions in 2016.

EPs who have not attested to meaningful use for 2014 face a dwindling window of time to do so by submitting their meaningful use data through the Medicare & Medicaid EHR Incentive Program Registration and Attestation System. It is also advisable for EPs and their practice entities to assemble related documentation supporting meaningful use so that they can promptly respond to any audit request, keeping in mind that meaningful use payments are subject to recoupment upon failure to document satisfaction of all meaningful use requirements. Moreover, retaining incentive payments when a provider fails to qualify could, in some cases, trigger exposure under the False Claims Act for failure to report and return overpayments.

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¹Medicare EPs include physicians, dentists, podiatrists, optometrists, and chiropractors, but not hospital-based physicians who furnish at least 90 percent of their services in a hospital inpatient or emergency room setting.