LONG BEACH, CALIF. — The inability to prescribe controlled substances electronically is slowing adoption of electronic prescribing, but financial incentives could make it worthwhile for physicians who see patients covered by Medicare to start “e-prescribing” now if they can, a consultant said.
The Centers for Medicare and Medicaid Services in 2009 began offering Medicare physicians, nurse practitioners, and physician assistants a 2% bonus in payments for participation in its electronic prescribing incentives program for 2009–2010.
The bonus for early adopters of e-prescribing drops to 1% in 2011–2012 and 0.5% in 2013, Rachelle F. Spiro said at the annual meeting of the American Medical Directors Association.
The early e-prescriber incentives were extended to long-term care settings this year. The incentives are not yet available for non-Medicare e-prescribers.
“Here's the hard part,” she added: Physicians who do not successfully adopt e-prescribing by 2012 will see a 1% reduction in Medicare payments for that year, a 1.5% drop for 2013, and a 2% reduction for 2014 and each subsequent year. The Department of Health and Human Services may exempt physicians with hardships, on a case-by-case basis only.
The Drug Enforcement Agency (DEA) does not allow controlled substances to be electronically prescribed, however, which “has hindered the adoption of electronic prescribing,” said Ms. Spiro, a pharmacist and consultant based in Las Vegas. “We've been told that CMS will be working with the DEA to put out final rules for electronic prescribing” of controlled substances, she said. Only a few days after she spoke, the agency published a proposed rule to that effect.
A pilot program for e-prescribing of controlled substances was conducted in Massachusetts, but not in long-term care settings.
Physicians do not need to preregister for the CMS e-prescribing incentive program and do not need to participate in the Physician Quality Reporting Initiative to participate, Ms. Spiro said.
Instructions and examples of how to submit claims under the e-prescribing incentive program are available on the CMS Web site at www.cms.hhs.gov/ERxIncentiveqnetsupport@sdps.org
Physicians can use their facility's electronic health record (EHR) system to send a prescription and to document it in the medical record, then bill for the incentive in much the same way they already handle billing.
Or physicians can turn to certified practice management systems that have an e-prescribing component or to stand-alone e-prescribing systems, if they come from an entity on the CMS list of qualified EHR vendors, she advised. She warned that prescriptions from these two types of systems generally go directly to the pharmacy and not necessarily to the nursing home, “so you're going to have to work out some other mechanism to get that communication to the facility.”
To file claims in the e-prescribing incentives program, report the e-prescribing numerator G-code G8553 to denote that at least one prescription was created during the patient encounter that was transmitted using a qualified e-prescribing system. Report the G-code on the same claim as the denominator billing code for the same beneficiary and the same date of service. Submit the e-prescribing G-code with a line-item charge of zero dollars ($0.00).
Denominator billing codes for e-prescribing include codes for services in nursing facilities (99304-99310 and 99315-99316), home visits (99341-99350), and others including domiciliary codes (99324-99328, 99334-99337, and 99346).
As of 2011, Medicare will be offering incentives for physicians in hospitals and ambulatory settings to switch all of their records to EHRs, but these incentives won't be available to long-term and post–acute care settings until 2013, Ms. Spiro said. Physicians must choose between the Medicare e-prescribing incentives and complete EHR incentives programs and cannot participate in both (because presumably the EHR would include an e-prescribing component).
However, the same Health Information Technology for Economic and Clinical Health Act that established the EHR incentives included a provision for state Medicaid programs to incentivize early adoption of e-prescribing. “Actually, those incentives are a lot better” than Medicare incentives, she said. Physicians in long-term care settings who see patients covered by Medicare and Medicaid may want to participate in both e-prescribing early-adopter programs rather than wait for the 2013 EHR incentives under Medicare.
For the long-term care setting, that's “probably a better value,” Ms. Spiro said.
Disclosures: Ms. Spiro reported having no relevant conflicts of interest.