Take the Carrot…Don't Wait For The Stick!

The Centers for Medicare and Medicaid Services (CMS) are currently offering eligible providers a carrot in the form of a percentage bonus to move to e-prescribing. The idea is to increase the level of patient care by sending an accurate, error-free and understandable prescription directly to a pharmacy from the point of care thereby reducing medication errors and enhancing patient medication safety. The Medicare Electronic Prescribing (eRx) Incentive Program, which began in 2009 and runs through 2013, provides bonus payments (2% in 2010, 1% 2011 and 2012, and .5% in 2013 on all allowable charges for services for the entire year) for e-prescribing when certain eligibility criteria are met, with bonus percentages being reduced over the span of the program.

But with every “carrot” program there is usually a stick that follows the voluntary period, and so it is with the eRx program. The CMS 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 respectfully.  

But here we are at the beginning of December 2010; there can’t possibly be a way to take advantage of this incentive program this year.  Well, that is not true.  The 2010 reporting criteria require that health care providers report e-prescribing for at least 25 eligible patient encounters and that Medicare account for at least 10% of the providers payer mix.

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 dietitians, 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.

To obtain the bonus, providers can report their use of e-prescribing in any of three ways.  The easiest method of reporting is to utilize the claims-based reporting by simply adding the G8553 code to a patient’s charge record. Alternatively providers can use the registry-based reporting or EMR-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.

Providers should take note that the window of eligibility for the bonus is still open for 2010. It is not too late to start reporting your e-prescribing for this year. Providers can start e-prescribing any time during the calendar year up to December 31, 2010.

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.