The Medicare E-Prescribe Incentives Program     

As you probably know, the Centers for Medicare and Medicaid Services (CMS) has offered an incentive program for e-prescribing for the last few years. What you may not know is that the Healthcare Reform Act, passed last year, allows for a penalty (also called a payment adjustment) for those eligible providers (defined as MD, DO, nurse practitioner, or physician assistant) who are not using e-prescribing, beginning January 1, 2012. Many practices thought that the 1% penalty would be assessed beginning January 1, 2012. However that is not the case.

Medicare has determined that the clock started January 1, 2011, and goes to June 30, 2011, so we are already about halfway through that timeframe. During this time frame, every eligible provider must prescribe at least 10 e-prescriptions meeting specific criteria.

If you do not complete the 10 e-prescriptions within the six month window, you will have that penalty assessed to your Medicare allowable charges, beginning January 1, 2012. So if you are not e-prescribing, it is time to start. It is time to get a qualified system and to start e-prescribing those ten patients.

What Happens After 2012?

There is an additional 1.5% penalty if you’re not e-prescribing in 2013 – and the clock started ticking January 1, 2011. So if you are not e-prescribing by the end of this year, you’ll be facing penalties in both 2012 and 2013. You will need 25 eRx fillings in 2011. CMS has not yet announced whether eRx fillings in 2012 will count toward avoiding penalties in 2013. Due to this ambiguity it is strongly recommended to not wait until 2012 to start filling.

Requirements for E-Prescribing

The requirement has been primarily for Medicare patients, however with the beginning of meaningful use criteria, the issue of e-prescribing will affect all of our patients, not just Medicare patients. The question that comes up frequently is, “Can I electronically fax my prescription to the pharmacy, and will that count?” The answer is no. In order to do e-prescribing, you must have an approved e-prescribing system.

Methods for E-Prescribing in 2011

If you want the e-prescription incentive, you will need to attach to an E&M code.  The G-code you would use for the incentive program is G8553. You must submit 25 e-prescriptions on your Medicare patients to get 1%. And you can do this under your claims or registry.

Avoiding Penalties

• To avoid penalties, 1% in 2012, and 1.5% in 2013, it is very important to attach an E&M code. You use the same “G” code, 8553.
• You must submit ten e-prescriptions on Medicare patients between January 1, 2011 and June 30, 2011 to avoid the 1% adjustment. It must be on claims. You cannot use a registry.
• You must submit 25 e-prescriptions on Medicare patients between January 1, 2011 and December 31, 2011 in order to avoid the 1.5% penalty in 2013.
• So just to summarize, the 2012 penalty is dependent on submission in the first six months of 2011, and the 2013 penalty is dependent on the entirety of 2011.  

Meaningful Use Requirements

• The key to meaningful use is that it is for all patients, not just Medicare patients.
• The second key, it is not tied to an E&M code, and you do not need to use G codes.
• Simply do e-prescribing on more than 40% of all your permissible prescriptions, on all patients, not just Medicare patients. This excludes controlled substances.
• You need to work with your EMR vendor as you do your planning. Running a report from your medication module may be an easy way to capture the e-prescriptions you are doing on at least 40% of your patients.

Follow Three Simple Steps

1. Identify the incentive money that is available to you
2. Identify the penalties that will be assessed in 2012 and 2013
3. Remember e-prescribing is embedded in meaningful use –

It’s relatively complex, but it’s very important to segregate these into the three different areas. This will ensure you get your e-prescribing incentive money, and avoid penalties in 2012 and 2013.

Finally, if you’re going to ask for your meaningful use money, you cannot go after e-prescribing incentive money as well. You either get one or the other. The penalties are a totally separate issue.

Related Posts:

• Appropriate Use Criteria in Electrophysiology
• Meaningful Use Basics: What You Need to Know Right Now