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E-Prescribing – Eligibility, Reporting, Incentives, Penalties, and Systems

Posted on January 3, 2012 | No Comments
Yuval Lirov asked:




The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorized incentives for physicians to utilize electronic prescribing (e-prescribing). The incentives took effect January 1st 2009. As is typical for Medicare, a carrot and stick approach has been implemented to encourage physicians to take part in the program. The following is summary of the salient points and some issues to consider regarding e-prescribing: Eligibility requirements:

Physician or other recognized health care practitioners (including Physician Assistants and Nurse Practitioners) At least 10% of annual Medicare charges per practitioner must come from a list of approved Medicare CPT codes. The designated code list is primarily comprised of common office visit, or outpatient consult CPT codes (e.g. 99203, 99213, 99243, 99244). Most office based primary care physicians and specialists should easily qualify for the 10% requirement Must use a qualified e-prescribing system (see below) Pertains only to patients enrolled in traditional Medicare. The e-prescribing initiative does not apply to patients in Medicare Advantage programs

How to report e-Prescribing to Medicare:

Three new G-codes have been developed by Medicare to designate e-prescribing;

G8443 to report that all prescriptions in connection with the visit billed were electronically prescribed G8445 to report that no prescriptions were generated during the visit G8446 to report that some or all prescriptions were written or phoned in due to patient request, State or Federal law, the pharmacy’s system being unable to receive the data electronically or because the prescription was for a narcotic or other controlled substance

Practitioners must include one of the above three G codes when they bill Medicare along with approved CPT codes to qualify the visit as an e-prescribing event At least 50% of Medicare applicable claims per year must be billed with a G code in order to qualify for the Medicare incentive

e-Prescribing incentives payments:

Payments are based upon the total allowed Part B charges billed by providers per annual reporting period Providers are paid a percentage of those charges based on the following schedule:

2.0% for 2009 2.0% for 2010 1.0% for 2011 1.0% for 2012 0.5% for 2013

e-Prescribing penalties:

Beginning in 2012, providers not reporting successful e-prescribing to Medicare will be penalized Penalties will also be based upon total allowed Part B charges billed by providers per annual reporting period Provider’s Medicare payments will be reduced according to the following schedule:

1.0% for 2012 1.5% for 2013 2.0% for 2014 and each subsequent year

Qualified e-Prescribing systems:

In order to qualify for the Medicare e-prescribing incentive, practitioners must use a qualified system Qualifying systems must support a strict list of functionalities and interoperability standards designated by CMS All EMR systems that obtain the Certification Commission for Health Information Technology (CCHIT) 2008 certification will qualify. In 2009, CCHIT will begin certification for stand-alone e-prescribing systems Practitioners should obtain written guarantees from e-prescribing or EMR vendors that the systems meet all CMS e-prescribing requirements

Types of e-Prescribing Systems

EMR system vs. stand-alone

Stand-alone systems make more sense for practices not planning on implementing EMR in the foreseeable future Stand-alone e-prescribing systems are generally less costly and simpler than EMR systems EMR systems’ e-prescribing applications may offer better functionality Unlike EMR, stand-alone systems many times are separate from practice management systems and thus may require double entry of data

Locally installed vs. web applications

Locally installed applications are installed and run directly on practices computers. Data is stored on computer(s) in the office Web services are accessed through the Internet. Data is stored on the web server Locally installed e-prescribing applications may have higher up-front costs and require maintenance such as data back-ups. Internet connections are not needed to access the applications but are necessary to transmit prescriptions Web services generally require the Internet to access the applications and may be slower than locally installed programs. Some practices may have concerns regarding storing clinical data on outside system

Hand-held or PC-based systems

Hand-held PDAs allow convenient access to e-prescribing applications and obviate the need and cost of computers in every location Hand-held applications generally do not have the same functionality and ease of use as PC-based e-prescribing systems Some e-prescribing applications allow for both hand-held and PC-based systems prescription writing

In 2009 there appears to be a significant increase in government support for medical practices to “go electronic” whether it be e-prescribing or EMR/EHR. Practices should consider implementing EMR and e-prescribing systems in the near to mid term to take advantage of subsidies and incentive payments. In the longer term, it is likely that support for electronic will turn into mandates from both government and private payers.

Additional resources are available at Surescripts, the nations largest electronic pharmacy network and the AMA online learning center for e-prescribing (AMA membership is needed for access of the entire site).

References:

Medicare’s Practical Guide to the E-prescribing Incentive Program, November, 2008 Overview of the Medicare 2009 E-Prescribing Incentive Program, ACP 2008 Considerations in Choosing an E-Prescribing System, ACP 2008

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