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Act Now to Avoid Medicare E-Prescribing Penalty


 

FROM THE ANNUAL MEETING OF THE AMERICAN COLLEGE OF CHEST PHYSICIANS

VANCOUVER, B.C. – The Centers for Medicare and Medicaid Services is currently offering providers a bonus for e-prescribing, or electronically transmitting prescriptions to pharmacies. But soon, providers will instead be hit with a penalty if they don’t get on board with this practice.

"They are really promoting this," Michael K. McCormick, a practice administrator at the DuPage Medical Group in Winfield, Ill., said at the annual meeting of the American College of Chest Physicians. But by transitioning from a bonus to a penalty over several years, "they are giving you time to get going on it."

Dr. Michael K. McCormick

The Medicare Electronic Prescribing (eRx) Incentive Program, which began in 2009 and runs through 2013, provides bonus payments for e-prescribing when certain eligibility criteria are met, with bonus percentages being reduced over the span of the program, according to Mr. McCormick, a registered respiratory therapist.

But the CMS also will start financially penalizing providers who do not begin e-prescribing in 2011. The penalty for failing to e-prescribe will be 1%, 1.5%, and 2% of all Medicare Part B charges in 2012, 2013, and 2014, respectively.

The bottom line is to "e-prescribe at least 10 times in the first 6 months of 2011 so you won’t be penalized in 2012," Mr. McCormick recommended. "You really need to start doing this in 2011."

The 2010 reporting criteria require that health care providers report e-prescribing for at least 25 eligible patient encounters (which can include multiple encounters for a single patient) and that Medicare account for at least 10% of the provider’s payer mix.

"The bonus returned to providers for 2010 is 2% of the total Medicare Part B Physician Fee Schedule allowed charges for services for the entire year; it will be 1% in 2011 and 2012, but only 0.5% in 2013.

All physicians (medical, osteopathic, podiatric, and chiropractic ones, among others) and a wide variety of allied health professionals (physician assistants, nurse practitioners, clinical social workers, and registered dieticians, among others) are eligible for the program.

The e-prescribing system used must meet certain criteria – for example, it must generate complete lists of all medications a patient is taking; provide information related to any lower-cost, therapeutically appropriate drugs; and, most notably, transmit prescriptions to pharmacies electronically.

Faxing of the prescription does not count, even if a computer system autogenerates the fax, Mr. McCormick cautioned. The prescription "must basically go from your computer to the pharmacy’s computer, not through a fax."

To obtain the bonus, providers can report their use of e-prescribing in any of three ways. "Probably the easiest way to get started is the claims-based reporting," he said, which entails simply adding the G8553 code to the other codes. Alternately, providers can use registry-based reporting or electronic health record (EHR)–based reporting.

The list of patient encounters considered eligible for e-prescribing is "pretty comprehensive," including all outpatient office visits (those having 992xx codes), home health visits, nursing home visits, and psychiatric care visits, he said. However, inpatient visits are not eligible.

A noteworthy caveat is that providers will not be able to earn both the e-prescribing bonus and another bonus for implementing the EHRs that the CMS is offering, because e-prescribing is among the 15 core measures of EHR implementation.

Put another way, "there is no double-dipping, starting in 2011," Mr. McCormick said. "So if you are going to go for that [EHR] bonus, which is a lot more money – $44,000 per provider paid over 5 years – you can’t put in for the eRx bonus as well."

Providers should take note that the window of eligibility for the bonus is still open for 2010. "It’s not too late ... to start e-prescribing for this year," he commented. "You can start e-prescribing any time during the year up to Dec. 31."

Certain providers will be exempt from the penalty, he added: those who generate fewer than 100 claims with eligible eRx patient codes, those for whom less than 10% of patient encounters are eligible (e.g., hospital-based physicians), and those facing relevant hardships, namely, practicing in a rural area with limited high-speed Internet service or a limited number of pharmacies able to receive prescriptions electronically.

The program’s rules, which change annually, can be found online.

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