You’re probably tired of reading about electronic prescribing by now, and I really thought I was done writing about it for the year when I summarized the "final" 2011 rules.
Now, however, CMS has proposed further rule modifications in the spirit, they say, of working with physicians to encourage the wider use of e-prescribing technology.
In order to qualify for the 2011 incentive, the rules required you to send at least 10 electronic Medicare or Medicaid prescriptions by the end of June (and report them to CMS using the G8553 code by the end of July), followed by a minimum of 15 more by the end of the year.
By Dr. Joseph S. Eastern
So if you missed the June deadline, you are ineligible for the 2011 incentive no matter what you do in the second half of 2011. But you can use the remainder of the year to prepare for 2012, the first year that failing to e-prescribe will incur a 1% penalty against Medicare/Medicaid payments. (In 2013 the penalty increases to 1.5%, and then to 2% in 2014 and beyond.)
Practices in rural areas, those without high-speed Internet access, and those lacking a sufficient number of pharmacies equipped to accept electronic prescriptions may apply for exemptions.
Now, CMS has proposed additional exemption opportunities for practices that write very few prescriptions, and those that write large numbers of prescriptions for drugs that cannot, by law, be prescribed electronically (such as most narcotics).
Offices that see very few Medicare or Medicaid patients can still qualify for the incentive if at least 10% of their Medicare Part B claims involve an electronic prescription.
As I mentioned previously, many electronic health record systems do not satisfy e-prescribing requirements because the prescription software simply generates faxes that arrive, on paper, in the pharmacy’s fax machine.
Under the proposed new rules, however, any certified electronic health records (EHR) system would be considered a "qualified" e-prescribing system, even those that don’t send prescriptions electronically. (The government’s other major goal, after all, is to increase EHR usage.)
To be clear, manual faxing of prescriptions to pharmacies will still not qualify as e-prescribing, which remains, by definition, computer-to-computer (paperless) communication of prescriptions. If you don’t have a qualified EHR, you will still need to use a qualified stand-alone e-prescribing system.
Either way, the e-prescribing G-code must be submitted with a line-item charge of zero dollars ($0.00) at the time the associated covered service is billed. Those line items will be denied for payment, but are passed through the claims processing system to the National Claims History database (NCH), which will keep track of your e-prescribing usage.
Fortunately, a coalition of insurance and technology companies called the National e-Prescribing Patient Safety Initiative (NEPSI) has made it quite easy to acquire free qualified e-prescribing technology. Setup methods vary, but the concepts and requirements for each company are generally similar. In most cases, all you need to get started is an Internet-enabled computer with a high-speed connection and a database of patients.
NEPSI has also encouraged pharmacies to make themselves compatible, and about 75% of them can now handle electronic prescriptions.
Keep in mind that this will not be a complete transition; once you’re set up, you cannot throw away your paper prescription pads.
Beside the pharmacies not yet equipped for e-prescribing, the Drug Enforcement Administration strongly discourages sending controlled substance prescriptions electronically. (The DEA has, however, relaxed its rules somewhat on this issue in the past year.)
A nonprofit foundation called eHealth Initiative has released an excellent guide for physicians on e-prescribing.
A list of other companies currently offering e-prescribing software, along with links to their respective websites, can be found at eprescribing.info.
Next year will be pivotal for electronic prescribing: If you are a Medicare or Medicaid participator you will either have to take the plunge or incur a penalty. However, with the free NEPSI program and only 25 e-prescriptions required over the course of an entire year, you can try out the technology with minimal cost and inconvenience.
Dr. Eastern practices dermatology and dermatologic surgery in Belleville, N.J.