Attestation requirements
DENOMINATOR/NUMERATOR/ THRESHOLD/EXCLUSION
* DENOMINATOR: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the EHR reporting period; or Number of prescriptions written for d rugs requiring a prescription in order to be dispensed during the EHR reporting period,
NUMERATOR: The number of prescriptions in the denominator generated, queried for a drug formulary and transmitted electronically using CEHRT,
THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP to meet this measure,
EXCLUSIONS: Any EP who:
(1) Writes fewer than 100 permissible prescriptions during the EHR reporting period; or
(2) Does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice Location at the start of his/her EHR reporting period.
Additional Information
. The provider is permitted, but not required, to Limit the measure of this objective to those patients whose records are maintained using certified EHR technology (CEHRT), Authorizations for items such as durable medical equipment, or other items and services that may require EP authorization before the patient could receive them, are not included in the definition of prescriptions. These are excluded from the numerator and the denominator of the measure ,
* Instances where patients specifically request a paper prescription may not be excluded from the denominator of this measure, The denominator includes all prescriptions written by the EP during the EHR reporting period.
As electronic prescribing of controlled substances is now possible, providers can choose to include aII prescriptions or only permissible prescriptions as long as the decision applies to all
patients and for the entire EHR reporting period, The determination of whether a prescription is a ''permissible prescription'' for purposes of this measure should be made based on the guidelines for prescribing Schedule II-V controlled substances in effect on or before January 13,
2010 ,
* An EP needs to use CEHRT as the sole means of creating the prescription, and when transmitting to an external pharmacy that is independent of the EP's organization such transmission must use standards adopted for EHR technology certification,
* EPs should include in the numerator and denominator both types of electronic transmissions (those within and outside the organization) for the measure of this objective,
* For purposes of counting prescriptions ''generated and transmitted electronically,'' we consider
the generation and transmission of prescriptions to occur concurrently if the prescriber and dispenser are the same person and/or are accessing the same record in an integrated EHR to creating an order in a system tiat is electronically transmitted to an internal pharmacy,
* Providers can use intermediary networks that convert information from the certified EHR into a computer-based fax in order to meet this measure as Long as the EP generates an electronic prescription and transmits it electronically using the standards of CEHRT to the intermediary network, and this results in the prescription being filled without the need for the provider to communicate the prescription in an alternative manner.
* Prescriptions transmitted electronically within an organization (the same legal entity) do not need to use the NCPDP standards, However, an EP's EHR must meet all applicable certification criteria and be certified as having tie capability of meeting the external transmission
requirements of 170,304(b), In addition, the EHR that is used to transmit prescriptions within tie organization would need to be CEHRT,
Showing posts with label E - prescription. Show all posts
Showing posts with label E - prescription. Show all posts
E-Prescitption program 2013 basic
2013 ERx Measure Specifications
Like previous years we need to report E-Prescription measures on atleast 10 claims for the reporting period January 1 through June 30, 2013 and atleast 25 claims (including the 10 claims) for the reporting period Jan 1 through December 31, 2013 inorder to receive ERx incentive payments. ERx measures if reported via claims the HCPCS code G8553 that denotes "At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system (not faxed from the eligible professional’s office)" should always be submitted along with any of the applicable visit codes (Denominators) listed below on the same claim.
Denominator codes:
90791, 90792, 90832, 90834, 90837, 90839, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
Please note:
ERx datas must be processed into the NCH (National Claims History database) no later than July 26, 2013
The eRx G-code can be reported on any Medicare Part B claim that includes a billable Part B service, regardless of whether the claim contains coding in the eRx measure’s denominator.
Eligible professionals who haven't met the ERx requirements (Reporting G8553 at least 25 times along with the above listed codes for the period from Jan 1 through December 31, 2012) can still request for an Hardship exemption till January 31, 2013 at the given below link
https://www.qualitynet.org/portal/server.pt/community/communications_support_system/234
Eligible professionals who doesn't meet the ERx requirement may end up with penalty of 1.5% adjustment in 2013 (eligible professional will receive 98.5% of their Medicare Part B PFS amount for covered professional services); and 2.0% adjustment in 2014 (eligible professional will receive 98% of their Medicare Part B PFS amount for covered professional services). Eligible Professionals list: http://cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ERxIncentive/Eligible-Professionals.html
Claims may NOT be resubmitted for the sole purpose of adding or correcting the G-code.
The ERx measure specification for the year 2013 has also been attached herewith for your review. Please communicate all of these to our Clients and encourage them for E-prescribing programs.
Like previous years we need to report E-Prescription measures on atleast 10 claims for the reporting period January 1 through June 30, 2013 and atleast 25 claims (including the 10 claims) for the reporting period Jan 1 through December 31, 2013 inorder to receive ERx incentive payments. ERx measures if reported via claims the HCPCS code G8553 that denotes "At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system (not faxed from the eligible professional’s office)" should always be submitted along with any of the applicable visit codes (Denominators) listed below on the same claim.
Denominator codes:
90791, 90792, 90832, 90834, 90837, 90839, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
Please note:
ERx datas must be processed into the NCH (National Claims History database) no later than July 26, 2013
The eRx G-code can be reported on any Medicare Part B claim that includes a billable Part B service, regardless of whether the claim contains coding in the eRx measure’s denominator.
Eligible professionals who haven't met the ERx requirements (Reporting G8553 at least 25 times along with the above listed codes for the period from Jan 1 through December 31, 2012) can still request for an Hardship exemption till January 31, 2013 at the given below link
https://www.qualitynet.org/portal/server.pt/community/communications_support_system/234
Eligible professionals who doesn't meet the ERx requirement may end up with penalty of 1.5% adjustment in 2013 (eligible professional will receive 98.5% of their Medicare Part B PFS amount for covered professional services); and 2.0% adjustment in 2014 (eligible professional will receive 98% of their Medicare Part B PFS amount for covered professional services). Eligible Professionals list: http://cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ERxIncentive/Eligible-Professionals.html
Claims may NOT be resubmitted for the sole purpose of adding or correcting the G-code.
The ERx measure specification for the year 2013 has also been attached herewith for your review. Please communicate all of these to our Clients and encourage them for E-prescribing programs.
Payment Adjustment Information - E-prescription
Electronic Prescribing (eRx) Payment Adjustment Information
Beginning 2012, Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (P.L.110-275) (MIPPA) requires CMS to subject eligible professionals who are not successful electronic prescribers under the eRx Incentive Program to a payment adjustment. This payment adjustment applies to all of the eligible professional's Part B-covered professional services under the Medicare Physician Fee Schedule (MPFS). From 2012 through 2014, the payment adjustment will increase with each new reporting period. Accordingly, for 2012, eligible professionals receiving a payment adjustment will be paid 1.0% less than the MPFS amount for that service. In 2013 and 2014, the payment adjustment increases to 1.5% and 2.0% respectively.
Significant Hardship Exception: Eligible professionals may be exempt from the application of the payment adjustment if CMS determines that compliance with the requirement for being a successful electronic prescriber would result in a significant hardship. This hardship exception is subject to annual renewal.
Beginning 2012, Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (P.L.110-275) (MIPPA) requires CMS to subject eligible professionals who are not successful electronic prescribers under the eRx Incentive Program to a payment adjustment. This payment adjustment applies to all of the eligible professional's Part B-covered professional services under the Medicare Physician Fee Schedule (MPFS). From 2012 through 2014, the payment adjustment will increase with each new reporting period. Accordingly, for 2012, eligible professionals receiving a payment adjustment will be paid 1.0% less than the MPFS amount for that service. In 2013 and 2014, the payment adjustment increases to 1.5% and 2.0% respectively.
Significant Hardship Exception: Eligible professionals may be exempt from the application of the payment adjustment if CMS determines that compliance with the requirement for being a successful electronic prescriber would result in a significant hardship. This hardship exception is subject to annual renewal.
2011 eRx Incentive Program rules and Regulations
Electronic Prescribing (eRx) Incentive Program Statutory Authority - Statute/Regulations
Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorized a new and separate program for eligible professionals who are successful electronic prescribers for 2009 through 2013, as detailed in MIPPA. A link to the MIPPA legislation can be found in the "Related Links Outside CMS" section below. For 2009 and 2010, the Secretary is authorized to provide successful electronic prescribers an incentive payment equal to 2.0% of the total estimated allowed charges submitted not later than 2 months after the end of the reporting period (January 1, 2009 – December 31, 2009). For 2011 and 2012, eligible professionals who are successful electronic prescribers may qualify to earn an incentive payment equal to 1.0% of the total estimated allowed charges submitted not later than 2 months after the end of the reporting period. For 2013, the incentive payment amount is reduced to 0.5%. Beginning in 2012, eligible professionals who are not successful electronic prescribers may be subject to a payment adjustment, or penalty. Specifically, for 2012 through 2014, if an eligible professional is not a successful electronic prescriber for the reporting period for the year, the PFS amount for covered professional services furnished by such professional during the year shall be less than the PFS amount that would otherwise apply by 1.0% for 2012, 1.5% for 2013, and 2.0% for 2014.
More detailed information regarding eligible professionals may be found by clicking on the "Eligible Professionals" section page to the left.
2011 eRx Proposed Rule
The Centers for Medicare & Medicaid Services released a proposed rule for changes to the Medicare Electronic Prescribing (eRx) Incentive Program. The proposed rule has been published in the Federal Register on June 1, 2011. The Federal Register published version has now been posted. To view the proposed rule, see link titled "2011 PFS Proposed Rule -- CMS-3248-P" in the "Related Links Outside CMS" section below. The deadline for submitting comments to the proposed rule is July 25, 2011.
2011 eRx Incentive Program Regulations
CMS' proposals for the 2011 eRx incentive as well as our proposals for implementing the eRx payment adjustment that begins in 2012 can be found in the 2011 Medicare Physician Fee Schedule (PFS) proposed rule. The 2011 PFS proposed rule was published in the Federal Register on July 13, 2010. The deadline for submitting comments to the proposed rule is August 24, 2010. To view the entire 2011 PFS proposed rule, including instructions for submitting comments, click on the "2011 PFS Proposed Rule -- CMS-1503-P" in below.
The 2011 eRx Incentive Program, including the requirements related to the eRx payment adjustment that begins in 2012, was finalized in the 2011 PFS final rule with comment period. The final regulation is on display at the Federal Register. To view the entire 2011 PFS final rule with comment period, see "2011 PFS Final Rule -- CMS-1503-FC" in below.
2010 eRx Incentive Program Regulations
CMS' proposals for the 2010 eRx Incentive Program, including the proposed criteria that CMS will use to determine what eligible professionals the eRx incentive applies to and how "successful electronic prescriber" will be defined for 2010, can be found in section G5 of the 2010 PFS proposed rule (74 FR 33593 through 33600). The 2010 PFS proposed rule was published in the Federal Register on July 13, 2009.
The 2010 eRx Incentive Program was finalized in the 2010 PFS final rule with comment period (74 FR 61849 through 61861). The final regulation was published in the Federal Register on November 25, 2009.
2009 E-Prescribing Incentive Program Regulations
Detailed information about the criteria that CMS will use to determine what eligible professionals the eRx incentive applies to and how "successful electronic prescriber" is defined for 2009 are described in section O2 of the final 2009 Physician Fee Schedule (PFS) rule (73 FR 69847 through 69852) that was published in the Federal Register on November 19, 2008.
Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorized a new and separate program for eligible professionals who are successful electronic prescribers for 2009 through 2013, as detailed in MIPPA. A link to the MIPPA legislation can be found in the "Related Links Outside CMS" section below. For 2009 and 2010, the Secretary is authorized to provide successful electronic prescribers an incentive payment equal to 2.0% of the total estimated allowed charges submitted not later than 2 months after the end of the reporting period (January 1, 2009 – December 31, 2009). For 2011 and 2012, eligible professionals who are successful electronic prescribers may qualify to earn an incentive payment equal to 1.0% of the total estimated allowed charges submitted not later than 2 months after the end of the reporting period. For 2013, the incentive payment amount is reduced to 0.5%. Beginning in 2012, eligible professionals who are not successful electronic prescribers may be subject to a payment adjustment, or penalty. Specifically, for 2012 through 2014, if an eligible professional is not a successful electronic prescriber for the reporting period for the year, the PFS amount for covered professional services furnished by such professional during the year shall be less than the PFS amount that would otherwise apply by 1.0% for 2012, 1.5% for 2013, and 2.0% for 2014.
More detailed information regarding eligible professionals may be found by clicking on the "Eligible Professionals" section page to the left.
2011 eRx Proposed Rule
The Centers for Medicare & Medicaid Services released a proposed rule for changes to the Medicare Electronic Prescribing (eRx) Incentive Program. The proposed rule has been published in the Federal Register on June 1, 2011. The Federal Register published version has now been posted. To view the proposed rule, see link titled "2011 PFS Proposed Rule -- CMS-3248-P" in the "Related Links Outside CMS" section below. The deadline for submitting comments to the proposed rule is July 25, 2011.
2011 eRx Incentive Program Regulations
CMS' proposals for the 2011 eRx incentive as well as our proposals for implementing the eRx payment adjustment that begins in 2012 can be found in the 2011 Medicare Physician Fee Schedule (PFS) proposed rule. The 2011 PFS proposed rule was published in the Federal Register on July 13, 2010. The deadline for submitting comments to the proposed rule is August 24, 2010. To view the entire 2011 PFS proposed rule, including instructions for submitting comments, click on the "2011 PFS Proposed Rule -- CMS-1503-P" in below.
The 2011 eRx Incentive Program, including the requirements related to the eRx payment adjustment that begins in 2012, was finalized in the 2011 PFS final rule with comment period. The final regulation is on display at the Federal Register. To view the entire 2011 PFS final rule with comment period, see "2011 PFS Final Rule -- CMS-1503-FC" in below.
2010 eRx Incentive Program Regulations
CMS' proposals for the 2010 eRx Incentive Program, including the proposed criteria that CMS will use to determine what eligible professionals the eRx incentive applies to and how "successful electronic prescriber" will be defined for 2010, can be found in section G5 of the 2010 PFS proposed rule (74 FR 33593 through 33600). The 2010 PFS proposed rule was published in the Federal Register on July 13, 2009.
The 2010 eRx Incentive Program was finalized in the 2010 PFS final rule with comment period (74 FR 61849 through 61861). The final regulation was published in the Federal Register on November 25, 2009.
2009 E-Prescribing Incentive Program Regulations
Detailed information about the criteria that CMS will use to determine what eligible professionals the eRx incentive applies to and how "successful electronic prescriber" is defined for 2009 are described in section O2 of the final 2009 Physician Fee Schedule (PFS) rule (73 FR 69847 through 69852) that was published in the Federal Register on November 19, 2008.
Alternative Reporting Mechanism - E-prescription
Eligible professionals do not have to enroll or file an intent to participate in the eRx Incentive Program. Professionals who choose to participate by reporting the eRx measure through claims can simply report the G-code on service lines of Medicare Part B Physician Fee Schedule (PFS) professional-services claims.
Beginning with the 2010 eRx Incentive program year, eligible professionals may also qualify to earn an eRx incentive by reporting the eRx measure to a qualified registry. Professionals participating in a registry that self-nominates and qualifies to submit data on behalf of eligible professionals for a particular program year should expect to receive more information from the registry on how to participate. Only registries qualified for the Physician Quality Reporting System are eligible to become qualified for purposes of submitting data on the eRx measure on behalf of eligible professionals.
In addition to the claims-based reporting mechanism and the registry-based reporting mechanism, CMS tested electronic health record (EHR) data submission, in cooperation with EHR vendors. After successful completion of the 2009 Physician Quality Reporting System EHR Testing Program and a determination that there was at least one "qualified" EHR vendor, an eligible professional may potentially be able to earn an eRx incentive payment through the EHR-based reporting mechanism beginning with the 2010 eRx Incentive Program (if the eligible professional is using one of the EHR products that CMS "qualified" in its 2009 Physician Quality Reporting System EHR Testing Program). Only an EHR vendor that is qualified for the Physician Quality Reporting System is eligible to become qualified for purposes of an eligible professional being able to earn an eRx incentive through submission of eRx measure data extracted from a qualified EHR product.
NEW! CMS Is Now Accepting Public Comment on Proposed 2012 Physician Quality Reporting System EHR Measure Specifications
The Centers for Medicare & Medicaid Services (CMS) is now accepting public comment on proposed Electronic Health Record (EHR) Measure Specifications under consideration for possible inclusion in the 2012 eRx Incentive Program for future program years.
2010 eRx Incentive Program
As described in the 2010 Medicare PFS final rule (to view the rule, click on the "Statute/Regulations" link at left), CMS retains the claims-based reporting mechanism. In addition, CMS will accept eRx measure data submitted by a qualified registry on behalf of an eligible professional or eRx measure data extracted from a qualified EHR product. Since only EHR products that are qualified for the Physician Quality Reporting System are eligible to become qualified for the eRx Incentive Program, this was contingent upon the successful completion of our 2009 Physician Quality Reporting System EHR Testing Program, a determination that one or more EHR vendors participating in the 2009 Physician Quality Reporting System EHR Testing Program was "qualified," and one or more qualified Physician Quality Reporting System EHR vendors notified us of their desire to have one or more of their products qualified for purposes of the 2010 eRx Incentive Program.
Registry-Based Submission for 2010 Incentive
To qualify to submit eRx measure data on behalf of eligible professionals seeking eRx incentive payments for 2010, registries must be qualified to submit 2010 Physician Quality Reporting System data on behalf of eligible professionals. To become qualified to submit 2010 Physician Quality Reporting System data on behalf of eligible professionals, and thus, be eligible to become qualified to submit 2010 eRx measure data on behalf of eligible professionals, registries are required to go through a self-nomination and vetting process if they are new to Physician Quality Reporting System registry reporting, or to notify CMS of their desire to continue Physician Quality Reporting System data submission in 2010 if they were qualified in 2009 and successfully submitted their users' quality data. To become qualified, registries must meet certain technical and other requirements specified by CMS.
The document "Registry Requirements for Submission of 2010 Physician Quality Reporting System Data on Behalf of Eligible Professionals" describes the high-level requirements for a registry to qualify to submit under the registry-based reporting alternatives for the 2010 Physician Quality Reporting System. This document also outlines how a registry can become qualified for 2010 Physician Quality Reporting System data submission. Any registry that wants to report the eRx measure for the 2010 eRx Incentive Program also will have to follow the requirements contained in this document. This document provides the data submission specifications for registry-based reporting to be utilized by the qualified registries.
An updated list of registries that have become "qualified" to submit quality data to CMS on behalf of their eligible professionals for 2010 Physician Quality Reporting System. This list consists of qualified registries for the 2008 and 2009 Physician Quality Reporting System that have successfully submitted 2008 Physician Quality Reporting System data on behalf of eligible professionals to us and that have notified us of their desire to submit 2010 eRx measure data on behalf of eligible professionals. Additional registries were added to the list of qualified registries for the 2010 eRx Incentive Program upon completion of the 2010 registry self-nomination process. The self-nomination process to qualify additional registries for the 2010 eRx Incentive Program was completed during summer 2010.
EHR-Based Submission for 2010 Incentive
To qualify to submit eRx measure data on behalf of eligible professionals or group practices seeking eRx incentive payments for 2010, EHR vendors must be qualified to report 2010 Physician Quality Reporting System EHR measures. In early 2010, CMS finished vetting EHR vendors that self-nominated to participate in the 2009 EHR Testing Program. EHR vendors that successfully completed the 2009 EHR Testing Program are qualified to report 2010 Physician Quality Reporting System EHR measures and may potentially be qualified to report the 2010 eRx measure. A list of qualified EHR vendors for the 2010 eRx Incentive Program is posted here.
Qualified Electronic Health Record (EHR) Vendors for 2010 Physician Quality Reporting System and Electronic Prescribing Incentive Programs
An updated list of EHR vendors and their programs that have become "qualified" to submit quality data to CMS by eligible professionals 2010 Physician Quality Reporting System reporting. Each of these EHR vendors has gone through a thorough vetting process for the product and version listed including checking their capability to provide the required Physician Quality Reporting System data elements for 10 Physician Quality Reporting System measures. Some EHRs are also capable of reporting the electronic prescribing measure. In addition to capturing the required data elements for the measure calculation, these "qualified" EHR products can also transmit the required information in the requested file format. While the listed EHR vendors and their EHR products have successfully completed the vetting process, CMS cannot guarantee that any other product or version of software from the listed vendors will be compatible for EHR based submission for Physician Quality Reporting System. Additional 2010 EHR products that passed "qualification" were posted by mid-January 2010.
2011 eRx Incentive Program
EHR-Based Submission for 2011 Incentive
To qualify to report the eRx measure for 2011, EHR vendors will need to be qualified to report 2011 Physician Quality Reporting System EHR measures. EHR vendors who wish to qualify to participate in the 2011 Physician Quality Reporting System EHR program must have submitted a self-nomination letter requesting inclusion in the 2011 Physician Quality Reporting System Testing Process in 2010 by no later than January 31, 2010. The 2011 Physician Quality Reporting System EHR vendor qualification process and requirements for the 2011 Physician Quality Reporting System EHR Testing Process are described in the "Requirements for EHR Vendors to Participate in the 2011 Physician Quality Reporting System EHR Program". Any EHR vendor that wants to report the eRx measure for the 2011 eRx Incentive Program also will need to have followed the requirements contained in this document.
Beginning with the 2010 eRx Incentive program year, eligible professionals may also qualify to earn an eRx incentive by reporting the eRx measure to a qualified registry. Professionals participating in a registry that self-nominates and qualifies to submit data on behalf of eligible professionals for a particular program year should expect to receive more information from the registry on how to participate. Only registries qualified for the Physician Quality Reporting System are eligible to become qualified for purposes of submitting data on the eRx measure on behalf of eligible professionals.
In addition to the claims-based reporting mechanism and the registry-based reporting mechanism, CMS tested electronic health record (EHR) data submission, in cooperation with EHR vendors. After successful completion of the 2009 Physician Quality Reporting System EHR Testing Program and a determination that there was at least one "qualified" EHR vendor, an eligible professional may potentially be able to earn an eRx incentive payment through the EHR-based reporting mechanism beginning with the 2010 eRx Incentive Program (if the eligible professional is using one of the EHR products that CMS "qualified" in its 2009 Physician Quality Reporting System EHR Testing Program). Only an EHR vendor that is qualified for the Physician Quality Reporting System is eligible to become qualified for purposes of an eligible professional being able to earn an eRx incentive through submission of eRx measure data extracted from a qualified EHR product.
NEW! CMS Is Now Accepting Public Comment on Proposed 2012 Physician Quality Reporting System EHR Measure Specifications
The Centers for Medicare & Medicaid Services (CMS) is now accepting public comment on proposed Electronic Health Record (EHR) Measure Specifications under consideration for possible inclusion in the 2012 eRx Incentive Program for future program years.
2010 eRx Incentive Program
As described in the 2010 Medicare PFS final rule (to view the rule, click on the "Statute/Regulations" link at left), CMS retains the claims-based reporting mechanism. In addition, CMS will accept eRx measure data submitted by a qualified registry on behalf of an eligible professional or eRx measure data extracted from a qualified EHR product. Since only EHR products that are qualified for the Physician Quality Reporting System are eligible to become qualified for the eRx Incentive Program, this was contingent upon the successful completion of our 2009 Physician Quality Reporting System EHR Testing Program, a determination that one or more EHR vendors participating in the 2009 Physician Quality Reporting System EHR Testing Program was "qualified," and one or more qualified Physician Quality Reporting System EHR vendors notified us of their desire to have one or more of their products qualified for purposes of the 2010 eRx Incentive Program.
Registry-Based Submission for 2010 Incentive
To qualify to submit eRx measure data on behalf of eligible professionals seeking eRx incentive payments for 2010, registries must be qualified to submit 2010 Physician Quality Reporting System data on behalf of eligible professionals. To become qualified to submit 2010 Physician Quality Reporting System data on behalf of eligible professionals, and thus, be eligible to become qualified to submit 2010 eRx measure data on behalf of eligible professionals, registries are required to go through a self-nomination and vetting process if they are new to Physician Quality Reporting System registry reporting, or to notify CMS of their desire to continue Physician Quality Reporting System data submission in 2010 if they were qualified in 2009 and successfully submitted their users' quality data. To become qualified, registries must meet certain technical and other requirements specified by CMS.
The document "Registry Requirements for Submission of 2010 Physician Quality Reporting System Data on Behalf of Eligible Professionals" describes the high-level requirements for a registry to qualify to submit under the registry-based reporting alternatives for the 2010 Physician Quality Reporting System. This document also outlines how a registry can become qualified for 2010 Physician Quality Reporting System data submission. Any registry that wants to report the eRx measure for the 2010 eRx Incentive Program also will have to follow the requirements contained in this document. This document provides the data submission specifications for registry-based reporting to be utilized by the qualified registries.
An updated list of registries that have become "qualified" to submit quality data to CMS on behalf of their eligible professionals for 2010 Physician Quality Reporting System. This list consists of qualified registries for the 2008 and 2009 Physician Quality Reporting System that have successfully submitted 2008 Physician Quality Reporting System data on behalf of eligible professionals to us and that have notified us of their desire to submit 2010 eRx measure data on behalf of eligible professionals. Additional registries were added to the list of qualified registries for the 2010 eRx Incentive Program upon completion of the 2010 registry self-nomination process. The self-nomination process to qualify additional registries for the 2010 eRx Incentive Program was completed during summer 2010.
EHR-Based Submission for 2010 Incentive
To qualify to submit eRx measure data on behalf of eligible professionals or group practices seeking eRx incentive payments for 2010, EHR vendors must be qualified to report 2010 Physician Quality Reporting System EHR measures. In early 2010, CMS finished vetting EHR vendors that self-nominated to participate in the 2009 EHR Testing Program. EHR vendors that successfully completed the 2009 EHR Testing Program are qualified to report 2010 Physician Quality Reporting System EHR measures and may potentially be qualified to report the 2010 eRx measure. A list of qualified EHR vendors for the 2010 eRx Incentive Program is posted here.
Qualified Electronic Health Record (EHR) Vendors for 2010 Physician Quality Reporting System and Electronic Prescribing Incentive Programs
An updated list of EHR vendors and their programs that have become "qualified" to submit quality data to CMS by eligible professionals 2010 Physician Quality Reporting System reporting. Each of these EHR vendors has gone through a thorough vetting process for the product and version listed including checking their capability to provide the required Physician Quality Reporting System data elements for 10 Physician Quality Reporting System measures. Some EHRs are also capable of reporting the electronic prescribing measure. In addition to capturing the required data elements for the measure calculation, these "qualified" EHR products can also transmit the required information in the requested file format. While the listed EHR vendors and their EHR products have successfully completed the vetting process, CMS cannot guarantee that any other product or version of software from the listed vendors will be compatible for EHR based submission for Physician Quality Reporting System. Additional 2010 EHR products that passed "qualification" were posted by mid-January 2010.
2011 eRx Incentive Program
EHR-Based Submission for 2011 Incentive
To qualify to report the eRx measure for 2011, EHR vendors will need to be qualified to report 2011 Physician Quality Reporting System EHR measures. EHR vendors who wish to qualify to participate in the 2011 Physician Quality Reporting System EHR program must have submitted a self-nomination letter requesting inclusion in the 2011 Physician Quality Reporting System Testing Process in 2010 by no later than January 31, 2010. The 2011 Physician Quality Reporting System EHR vendor qualification process and requirements for the 2011 Physician Quality Reporting System EHR Testing Process are described in the "Requirements for EHR Vendors to Participate in the 2011 Physician Quality Reporting System EHR Program". Any EHR vendor that wants to report the eRx measure for the 2011 eRx Incentive Program also will need to have followed the requirements contained in this document.
eRx Incentive Program - Analysis and Payment
Incentive Payments
Eligible professionals who participate in the Electronic Prescribing (eRx) Incentive Program by reporting on their adoption and use of a qualified eRx system that has the functionalities required by CMS may qualify for an incentive payment.
Electronic prescribing is the transmission of prescription or prescription-related information through electronic media. The Medicare Improvements for Patients and Providers Act of 2008 (known as MIPPA) authorized the Medicare Electronic Prescribing Incentive Program to promote adoption and use of electronic-prescribing systems. With eRx, health care professionals can electronically transmit both new prescriptions and responses to renewal requests to a pharmacy without having to write or fax the prescription.
The eRx incentive payment is similar to the Physician Quality Reporting Initiative, or PQRI incentive in that it is based on the Medicare Part B Physician Fee Schedule (PFS) covered professional services furnished by the eligible professional during a reporting period. To be eligible for the incentive, you must meet the criteria for being a successful electronic prescriber. The criteria used to determine whether an eligible professional is a successful electronic prescriber are established for each program year through rulemaking.
Below are the authorized incentive payment amounts for each program year:
• 2009 eRx – 2.0%; and
• 2010 eRx – 2.0%.
Incentive payments for each program year are issued separately as a single consolidated incentive payment in the following year. Incentive payments are issued to the first valid group location listed under the Taxpayer Identification Number (TIN); or, for solo practitioners, to the first valid practice location listed under the TIN. The Carrier/MAC will make the payment electronically or via check, based on how the TIN normally receives payment for Medicare Part B PFS covered professional services furnished to Medicare beneficiaries. If a TIN submits claims to multiple Medicare claims-processing contractors (Carriers or MACs), each contractor may be responsible for a proportion of the TIN incentive payment equivalent to the proportion of Medicare Part B PFS claims the contractor processed during the applicable reporting period. (Note: If splitting an incentive across contractors would result in any contractor issuing an eRx incentive payment less than $20 to the TIN, the incentive will be issued by fewer contractors than may have processed PFS from the TIN for the reporting period). The eRx incentive payment can be offset by an outstanding debt for the TIN.
The incentive payment, with the remittance advice, will be issued by Carrier/MAC and identified as a lump-sum eRx incentive payment. Effective January 2010, CMS revised the manner in which incentive payment information is communicated to eligible professionals receiving electronic remittance advices. CMS has instructed Medicare contractors to use a new indicator of LE to indicate incentive payments instead of LS. LE will appear on the electronic remit. In an effort to further clarify the type of incentive payment issued (either PQRI or eRx incentive), CMS created a 4-digit code to indicate the type of incentive and reporting year. For the 2009 eRx incentive payments, the 4-digit code is RX09. This code will be displayed on the electronic remittance advice along with the LE indicator. For example, eligible professionals will see the LE to indicate an incentive payment, along with RX09 to identify that payment as the 2009 eRx incentive payment. Additionally, the paper remittance advice will read, "This is an ERx incentive payment." The year will not be included in the paper remittance.
Once we begin distributing incentive payments for a particular program year and your lump-sum incentive does not arrive or the incentive payment amount does not match what is reflected in your eRx Incentive Program feedback report, contact your Carrier/MAC (click on the "Help Desk Support" link at left for contact information). Note: The incentive amount may differ by a penny or two from what is reflected in your feedback report due to rounding.
eRx Incentive Program Feedback Reports
The eRx incentive payments and the eRx feedback reports are issued through separate processes (click on the appropriate "eRx Program" link at left for information specific to a particular program year). eRx Incentive Program feedback report availability is not based on whether or not an incentive payment was earned. Feedback reports will be available for every TIN under which at least one eligible professional (identified by his or her National Provider Identifier, or NPI) submitting Medicare Part B PFS claims reported the eRx measure a minimum of once during the reporting period.
Eligible professionals who participate in the Electronic Prescribing (eRx) Incentive Program by reporting on their adoption and use of a qualified eRx system that has the functionalities required by CMS may qualify for an incentive payment.
Electronic prescribing is the transmission of prescription or prescription-related information through electronic media. The Medicare Improvements for Patients and Providers Act of 2008 (known as MIPPA) authorized the Medicare Electronic Prescribing Incentive Program to promote adoption and use of electronic-prescribing systems. With eRx, health care professionals can electronically transmit both new prescriptions and responses to renewal requests to a pharmacy without having to write or fax the prescription.
The eRx incentive payment is similar to the Physician Quality Reporting Initiative, or PQRI incentive in that it is based on the Medicare Part B Physician Fee Schedule (PFS) covered professional services furnished by the eligible professional during a reporting period. To be eligible for the incentive, you must meet the criteria for being a successful electronic prescriber. The criteria used to determine whether an eligible professional is a successful electronic prescriber are established for each program year through rulemaking.
Below are the authorized incentive payment amounts for each program year:
• 2009 eRx – 2.0%; and
• 2010 eRx – 2.0%.
Incentive payments for each program year are issued separately as a single consolidated incentive payment in the following year. Incentive payments are issued to the first valid group location listed under the Taxpayer Identification Number (TIN); or, for solo practitioners, to the first valid practice location listed under the TIN. The Carrier/MAC will make the payment electronically or via check, based on how the TIN normally receives payment for Medicare Part B PFS covered professional services furnished to Medicare beneficiaries. If a TIN submits claims to multiple Medicare claims-processing contractors (Carriers or MACs), each contractor may be responsible for a proportion of the TIN incentive payment equivalent to the proportion of Medicare Part B PFS claims the contractor processed during the applicable reporting period. (Note: If splitting an incentive across contractors would result in any contractor issuing an eRx incentive payment less than $20 to the TIN, the incentive will be issued by fewer contractors than may have processed PFS from the TIN for the reporting period). The eRx incentive payment can be offset by an outstanding debt for the TIN.
The incentive payment, with the remittance advice, will be issued by Carrier/MAC and identified as a lump-sum eRx incentive payment. Effective January 2010, CMS revised the manner in which incentive payment information is communicated to eligible professionals receiving electronic remittance advices. CMS has instructed Medicare contractors to use a new indicator of LE to indicate incentive payments instead of LS. LE will appear on the electronic remit. In an effort to further clarify the type of incentive payment issued (either PQRI or eRx incentive), CMS created a 4-digit code to indicate the type of incentive and reporting year. For the 2009 eRx incentive payments, the 4-digit code is RX09. This code will be displayed on the electronic remittance advice along with the LE indicator. For example, eligible professionals will see the LE to indicate an incentive payment, along with RX09 to identify that payment as the 2009 eRx incentive payment. Additionally, the paper remittance advice will read, "This is an ERx incentive payment." The year will not be included in the paper remittance.
Once we begin distributing incentive payments for a particular program year and your lump-sum incentive does not arrive or the incentive payment amount does not match what is reflected in your eRx Incentive Program feedback report, contact your Carrier/MAC (click on the "Help Desk Support" link at left for contact information). Note: The incentive amount may differ by a penny or two from what is reflected in your feedback report due to rounding.
eRx Incentive Program Feedback Reports
The eRx incentive payments and the eRx feedback reports are issued through separate processes (click on the appropriate "eRx Program" link at left for information specific to a particular program year). eRx Incentive Program feedback report availability is not based on whether or not an incentive payment was earned. Feedback reports will be available for every TIN under which at least one eligible professional (identified by his or her National Provider Identifier, or NPI) submitting Medicare Part B PFS claims reported the eRx measure a minimum of once during the reporting period.
How to do E-prescribing report for Group practice
E-Prescribing Group Practice Reporting Option
In accordance with section 1848(m)(3)(C) of the Social Security Act (the Act), CMS is introducing a new group practice reporting option (GPRO) for the Electronic Prescribing (eRx) Incentive Program beginning with the 2010 eRx Incentive Program. Group practices that are successful electronic prescribers for a particular reporting period are eligible to earn an eRx incentive payment equal to a specified percentage of the group practice's total estimated Medicare Part B PFS allowed charges for covered professional services furnished during the reporting period. For the 2010 eRx Incentive Program, the incentive payment is equal to 2% of the group practice's total estimated Medicare Part B PFS allowed charges for covered professional services furnished during the 2010 reporting period. As required by section 1848(m)(3)(C)(iii) of the Act, an individual eligible professional who is a member of a group practice selected to participate in the eRx GPRO is not eligible to separately earn an eRx incentive payment as an individual eligible professional under that same Tax Identification Number (TIN) (that is, for the same TIN/National Provider Identifier, or NPI, combination). Once a group practice (TIN) is selected to participate in the GPRO, this is the only method of eRx reporting available to the group and all individual NPIs who bill Medicare under the group's TIN.
2011 eRx GPRO
GPRO Requirements for Submission of 2011 eRx Data. While participation in the eRx Incentive Program (either as an individual eligible professional or under the eRx GPRO) is voluntary for group practices participating in the Physician Quality Reporting System GPRO, CMS requires that in order for a group practice to participate in the 2011 eRx GPRO, a group practice must comply with all requirements for participation in the Physician Quality Reporting System GPRO and be participating in the Physician Quality Reporting System GPRO for 2011. A group practice that wishes to participate in both the Physician Quality Reporting System GPRO and in the eRx GPRO, must notify CMS of its desire to do so when self-nominating for the 2011 Physician Quality Reporting System GPRO.
2010 eRx GPRO
GPRO Requirements for Submission of 2010 eRx Data. While participation in the eRx Incentive Program (either as an individual eligible professional or under the eRx GPRO) is voluntary for group practices participating in the Physician Quality Reporting System GPRO, CMS requires that in order for a group practice to participate in the 2010 eRx GPRO, a group practice must comply with all requirements for participation in the Physician Quality Reporting System GPRO and be participating in the Physician Quality Reporting System GPRO for 2010. A group practice that wishes to participate in both the Physician Quality Reporting System GPRO and in the eRx GPRO, must notify CMS of its desire to do so when self-nominating for the 2010 Physician Quality Reporting System GPRO. The Physician Quality Reporting System GPRO requirements and instructions for submitting the self-nomination letter can be found in the "Downloads" section below. Additional information on the Physician Quality Reporting System GPRO can also be found by clicking on the "Physician Quality Reporting System GPRO" link under the "Related Links Inside CMS" section below.
2010 Criteria for Determining Whether a Group Practice is a Successful Electronic Prescriber Under the 2010 eRx GPRO. For purposes of determining whether a group practice is a successful electronic prescriber for 2010, each group practice selected to participate in the 2010 eRx GPRO will be required to report the eRx measure either through claims, a qualified registry, or a qualified EHR product.
The specifications for the eRx measure for use in the 2010 eRx GPRO can be found in the section below. For purposes of the 2010 eRx Incentive Program, a successful group practice electronic prescriber, must report the eRx measure for a minimum of 2,500 unique denominator-eligible visits per year. Attempts to report the measure for visits not associated with a denominator eligible patient visit do not count towards the minimum of 2,500.
In addition to meeting the criteria for "successful electronic prescriber" above, at least 10% of the group practice's Medicare Part B charges must be comprised of the codes in the denominator of the measure in order for the group practice to be incentive eligible.
In accordance with section 1848(m)(3)(C) of the Social Security Act (the Act), CMS is introducing a new group practice reporting option (GPRO) for the Electronic Prescribing (eRx) Incentive Program beginning with the 2010 eRx Incentive Program. Group practices that are successful electronic prescribers for a particular reporting period are eligible to earn an eRx incentive payment equal to a specified percentage of the group practice's total estimated Medicare Part B PFS allowed charges for covered professional services furnished during the reporting period. For the 2010 eRx Incentive Program, the incentive payment is equal to 2% of the group practice's total estimated Medicare Part B PFS allowed charges for covered professional services furnished during the 2010 reporting period. As required by section 1848(m)(3)(C)(iii) of the Act, an individual eligible professional who is a member of a group practice selected to participate in the eRx GPRO is not eligible to separately earn an eRx incentive payment as an individual eligible professional under that same Tax Identification Number (TIN) (that is, for the same TIN/National Provider Identifier, or NPI, combination). Once a group practice (TIN) is selected to participate in the GPRO, this is the only method of eRx reporting available to the group and all individual NPIs who bill Medicare under the group's TIN.
2011 eRx GPRO
GPRO Requirements for Submission of 2011 eRx Data. While participation in the eRx Incentive Program (either as an individual eligible professional or under the eRx GPRO) is voluntary for group practices participating in the Physician Quality Reporting System GPRO, CMS requires that in order for a group practice to participate in the 2011 eRx GPRO, a group practice must comply with all requirements for participation in the Physician Quality Reporting System GPRO and be participating in the Physician Quality Reporting System GPRO for 2011. A group practice that wishes to participate in both the Physician Quality Reporting System GPRO and in the eRx GPRO, must notify CMS of its desire to do so when self-nominating for the 2011 Physician Quality Reporting System GPRO.
2010 eRx GPRO
GPRO Requirements for Submission of 2010 eRx Data. While participation in the eRx Incentive Program (either as an individual eligible professional or under the eRx GPRO) is voluntary for group practices participating in the Physician Quality Reporting System GPRO, CMS requires that in order for a group practice to participate in the 2010 eRx GPRO, a group practice must comply with all requirements for participation in the Physician Quality Reporting System GPRO and be participating in the Physician Quality Reporting System GPRO for 2010. A group practice that wishes to participate in both the Physician Quality Reporting System GPRO and in the eRx GPRO, must notify CMS of its desire to do so when self-nominating for the 2010 Physician Quality Reporting System GPRO. The Physician Quality Reporting System GPRO requirements and instructions for submitting the self-nomination letter can be found in the "Downloads" section below. Additional information on the Physician Quality Reporting System GPRO can also be found by clicking on the "Physician Quality Reporting System GPRO" link under the "Related Links Inside CMS" section below.
2010 Criteria for Determining Whether a Group Practice is a Successful Electronic Prescriber Under the 2010 eRx GPRO. For purposes of determining whether a group practice is a successful electronic prescriber for 2010, each group practice selected to participate in the 2010 eRx GPRO will be required to report the eRx measure either through claims, a qualified registry, or a qualified EHR product.
The specifications for the eRx measure for use in the 2010 eRx GPRO can be found in the section below. For purposes of the 2010 eRx Incentive Program, a successful group practice electronic prescriber, must report the eRx measure for a minimum of 2,500 unique denominator-eligible visits per year. Attempts to report the measure for visits not associated with a denominator eligible patient visit do not count towards the minimum of 2,500.
In addition to meeting the criteria for "successful electronic prescriber" above, at least 10% of the group practice's Medicare Part B charges must be comprised of the codes in the denominator of the measure in order for the group practice to be incentive eligible.
E-Prescribing Incentive Program - How To Get Started
IT'S NOT TOO LATE TO START……
It's not too late to start participating in the 2011 Electronic Prescribing (eRx) Incentive Program and potentially qualify to receive a full-year incentive payment for 2011. In addition, beginning 2012, CMS will apply payment adjustments to eligible professional who are not successful electronic prescribers under the eRx Incentive Program. To become successful electronic prescribers for purposes of avoiding the 2012 eRx payment adjustment, eligible professionals must report the eRx measure for a required minimum number of unique eRx events via claims between January 1, 2011 and June 30, 2011. This web site section is designed to lead you step by step through the process of becoming one of the growing number of eligible professionals who are participating in the program. You may also wish to investigate participating in a separate program known as the Physician Quality Reporting System (formerly known as the Physician Quality Reporting Initiative, or PQRI). For information on the Physician Quality Reporting System go to the "Related Links Inside CMS" section of this page and click on the link titled Physician Quality Reporting System.
Eligible professionals may begin reporting the eRx measure at any time throughout the 2011 program year of January 1-December 31, 2011 to be incentive eligible, but must do so prior to June 30, 2011 to be exempt from the 2012 eRx payment adjustment (click on "Payment Adjustment" link on the left for more information. Click on the "Eligible Professional" link on the left to see if you are an eligible professional. Eligible professionals must have adopted a "qualified" eRx system in order to be able to report the eRx measure. There are two types of systems.
1) a system for eRx only (stand-alone)
2) an electronic health record (EHR system) with eRx functionality.
Regardless of the type of system used, to be considered "qualified" it must be based on ALL of the following capabilities:
• Generating a complete active medication list incorporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs) if available.
• Selecting medications, printing prescriptions, electronically transmitting prescriptions, and conducting all alerts.
• Providing information related to lower cost, therapeutically appropriate alternatives (if any). (The availability of an eRx system to receive tiered formulary information, if available, would meet this requirement for 2011)
• Providing information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient's drug plan, if available.
If you have not yet participated in the eRx Incentive Program, you can begin by reporting eRx data for January 1-December 31, 2011 using any of the following three options for purposes of qualifying for the 2011 incentive:
1. Claims-based reporting of the eRx measure. Report only one G-code (G8553) for 2011.
2. Registry-based reporting using a CMS-selected *registry to submit 2011 data to CMS during the first quarter of 2012.
3. EHR-based reporting using a CMS-selected *electronic health record product, submitting 2011 data to CMS during the first quarter of 2012
*Only registries and EHR vendors who have been vetted by CMS for the 2011 Physician Quality Reporting System/eRx Incentive Program and are on the posted list of registries/EHR vendors are eligible to be considered "qualified" for purposes of reporting the 2011 eRx Incentive Program. These registries/EHR vendors are qualified to report eRx information to CMS. However, please note that their systems have not been checked for eRx functionality as defined in the specifications of the measure. A list of EHR Vendors for the 2011 eRx Incentive Program is available in the "Downloads" section of this page. A list of qualified registries for the 2011 eRx Incentive Program will be available later this year.
For purposes of the 2012 payment adjustment, you need to report eRx data for January 1, 2011 through June 30, 2011 via claims. Before you report this measure, you should ask yourself the following questions:
QUESTION 1: Do I have an eRx system/program and am I routinely using it?
QUESTION 2: Is my system capable of performing the functions of a qualified system as described above?
QUESTION 3: Do I expect my Medicare Part B Physician Fee Schedule (PFS) charges for the codes in the denominator of the measure (as noted in List 1) to make up at least 10 percent of my total Medicare Part B PFS allowed charges for 2010?
If the answer to all three questions is YES, you may be eligible for an incentive payment equal to one percent as well as a one percent payment adjustment of your Medicare Part B PFS allowed charges for services furnished during the reporting period and you should report the eRx measure.
If the answer to the first two questions is YES, but the answer to the third question is NO, you may not be eligible for the incentive payment or the payment adjustment. However, we encourage you to report the eRx measure. In the event that your Medicare Part B PFS charges for the codes in the denominator of the measure (as noted in List 2) do make up at least 10 percent of your total Medicare Part B PFS allowed charges for 2010, you may be eligible for the incentive payment and payment adjustment.
If the answer to either of the first two questions is NO, you cannot report this measure unless you obtain and use a qualified eRx system as defined in List 1.
List 1: ERx Measure Denominator Codes (Eligible Cases)
Patient visit during the reporting period (Current Procedural Terminology [CPT] or Healthcare Common Procedure Coding System [HCPCS] G-codes):
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
CPT only copyright 2010 American Medical Association. All rights reserved.
Once You Have Decided That You Want to Participate in the eRx Incentive Program for 2011, You Should Take the Following Steps to Report the Measure:
STEP 1: Did you bill one of the CPT or HCPCS G-codes noted in List 1for the patient you are seeing?
NO: You do not need to report this measure for this patient for this visit.
YES: Proceed to Step 2.
STEP 2: You should report the following G-code (or numerator code) on the claim form that is submitted for the Medicare patient visit.
G8553 - At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.
We encourage you to report the G-code listed in Step 2 above on all of your patient visit claims along with one (or more) of the eligible denominator codes noted in List 1 above. An example of reporting the eRx measure on the Form CMS-1500 (Health Insurance Claim Form) is available in the "Downloads" section of this page. Click on the link titled "eRx Claims Based Reporting Principles".
STEP 3: To be a successful electronic prescriber and be eligible to receive an eRx incentive payment, you must generate and report one or more electronic prescriptions associated with a patient visit; a minimum of 25 unique visits per year. To avoid the 2012 eRx payment adjustment, you must report on a minimum of 10 unique visits via claims from January 1, 2011 through June 30, 2011. Each visit must be accompanied by the eRx G-code attesting that during the patient visit at least one prescription was electronically prescribed. Electronically generated refills do not count and faxes do not qualify as an electronic prescription. New prescriptions not associated with a code in the denominator of the measure specification are not accepted as an eligible patient visit and do not count towards the minimum unique eRx events.
STEP 4: Additionally, 10 percent of an eligible professional's Medicare Part B PFS charges must be comprised of the codes in the denominator of the measure to be eligible for an incentive or payment adjustment.
There is NO need to register to participate in this reporting program. Simply begin submitting the G-code on your claims appropriately, or, for eligible professionals attempting to quality for the incentive only, report the information required by the measure to a qualified registry, or submit the information required by the measure to CMS via a qualified EHR, if you satisfy the above requirements.
Other ways an eligible professional may avoid the 2012 payment adjustment are if the eligible professional:
• Is not a physician (MD, DO, or podiatrist), nurse practitioner, or physician assistant as of June 30, 2011, based on primary taxonomy code in the National Plan and Provider Enumeration System (NPPES);
• Does not have prescribing privileges and reports G-code G8644 (defined as not having prescribing privileges) at least one time on an eligible claim prior to June 30, 2011;
• Does not have at least 100 cases containing an encounter code in the measure denominator
• Does not meet the 10% denominator threshold
• Meets and reports a significant hardship exemption.
It's not too late to start participating in the 2011 Electronic Prescribing (eRx) Incentive Program and potentially qualify to receive a full-year incentive payment for 2011. In addition, beginning 2012, CMS will apply payment adjustments to eligible professional who are not successful electronic prescribers under the eRx Incentive Program. To become successful electronic prescribers for purposes of avoiding the 2012 eRx payment adjustment, eligible professionals must report the eRx measure for a required minimum number of unique eRx events via claims between January 1, 2011 and June 30, 2011. This web site section is designed to lead you step by step through the process of becoming one of the growing number of eligible professionals who are participating in the program. You may also wish to investigate participating in a separate program known as the Physician Quality Reporting System (formerly known as the Physician Quality Reporting Initiative, or PQRI). For information on the Physician Quality Reporting System go to the "Related Links Inside CMS" section of this page and click on the link titled Physician Quality Reporting System.
Eligible professionals may begin reporting the eRx measure at any time throughout the 2011 program year of January 1-December 31, 2011 to be incentive eligible, but must do so prior to June 30, 2011 to be exempt from the 2012 eRx payment adjustment (click on "Payment Adjustment" link on the left for more information. Click on the "Eligible Professional" link on the left to see if you are an eligible professional. Eligible professionals must have adopted a "qualified" eRx system in order to be able to report the eRx measure. There are two types of systems.
1) a system for eRx only (stand-alone)
2) an electronic health record (EHR system) with eRx functionality.
Regardless of the type of system used, to be considered "qualified" it must be based on ALL of the following capabilities:
• Generating a complete active medication list incorporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs) if available.
• Selecting medications, printing prescriptions, electronically transmitting prescriptions, and conducting all alerts.
• Providing information related to lower cost, therapeutically appropriate alternatives (if any). (The availability of an eRx system to receive tiered formulary information, if available, would meet this requirement for 2011)
• Providing information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient's drug plan, if available.
If you have not yet participated in the eRx Incentive Program, you can begin by reporting eRx data for January 1-December 31, 2011 using any of the following three options for purposes of qualifying for the 2011 incentive:
1. Claims-based reporting of the eRx measure. Report only one G-code (G8553) for 2011.
2. Registry-based reporting using a CMS-selected *registry to submit 2011 data to CMS during the first quarter of 2012.
3. EHR-based reporting using a CMS-selected *electronic health record product, submitting 2011 data to CMS during the first quarter of 2012
*Only registries and EHR vendors who have been vetted by CMS for the 2011 Physician Quality Reporting System/eRx Incentive Program and are on the posted list of registries/EHR vendors are eligible to be considered "qualified" for purposes of reporting the 2011 eRx Incentive Program. These registries/EHR vendors are qualified to report eRx information to CMS. However, please note that their systems have not been checked for eRx functionality as defined in the specifications of the measure. A list of EHR Vendors for the 2011 eRx Incentive Program is available in the "Downloads" section of this page. A list of qualified registries for the 2011 eRx Incentive Program will be available later this year.
For purposes of the 2012 payment adjustment, you need to report eRx data for January 1, 2011 through June 30, 2011 via claims. Before you report this measure, you should ask yourself the following questions:
QUESTION 1: Do I have an eRx system/program and am I routinely using it?
QUESTION 2: Is my system capable of performing the functions of a qualified system as described above?
QUESTION 3: Do I expect my Medicare Part B Physician Fee Schedule (PFS) charges for the codes in the denominator of the measure (as noted in List 1) to make up at least 10 percent of my total Medicare Part B PFS allowed charges for 2010?
If the answer to all three questions is YES, you may be eligible for an incentive payment equal to one percent as well as a one percent payment adjustment of your Medicare Part B PFS allowed charges for services furnished during the reporting period and you should report the eRx measure.
If the answer to the first two questions is YES, but the answer to the third question is NO, you may not be eligible for the incentive payment or the payment adjustment. However, we encourage you to report the eRx measure. In the event that your Medicare Part B PFS charges for the codes in the denominator of the measure (as noted in List 2) do make up at least 10 percent of your total Medicare Part B PFS allowed charges for 2010, you may be eligible for the incentive payment and payment adjustment.
If the answer to either of the first two questions is NO, you cannot report this measure unless you obtain and use a qualified eRx system as defined in List 1.
List 1: ERx Measure Denominator Codes (Eligible Cases)
Patient visit during the reporting period (Current Procedural Terminology [CPT] or Healthcare Common Procedure Coding System [HCPCS] G-codes):
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
CPT only copyright 2010 American Medical Association. All rights reserved.
Once You Have Decided That You Want to Participate in the eRx Incentive Program for 2011, You Should Take the Following Steps to Report the Measure:
STEP 1: Did you bill one of the CPT or HCPCS G-codes noted in List 1for the patient you are seeing?
NO: You do not need to report this measure for this patient for this visit.
YES: Proceed to Step 2.
STEP 2: You should report the following G-code (or numerator code) on the claim form that is submitted for the Medicare patient visit.
G8553 - At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.
We encourage you to report the G-code listed in Step 2 above on all of your patient visit claims along with one (or more) of the eligible denominator codes noted in List 1 above. An example of reporting the eRx measure on the Form CMS-1500 (Health Insurance Claim Form) is available in the "Downloads" section of this page. Click on the link titled "eRx Claims Based Reporting Principles".
STEP 3: To be a successful electronic prescriber and be eligible to receive an eRx incentive payment, you must generate and report one or more electronic prescriptions associated with a patient visit; a minimum of 25 unique visits per year. To avoid the 2012 eRx payment adjustment, you must report on a minimum of 10 unique visits via claims from January 1, 2011 through June 30, 2011. Each visit must be accompanied by the eRx G-code attesting that during the patient visit at least one prescription was electronically prescribed. Electronically generated refills do not count and faxes do not qualify as an electronic prescription. New prescriptions not associated with a code in the denominator of the measure specification are not accepted as an eligible patient visit and do not count towards the minimum unique eRx events.
STEP 4: Additionally, 10 percent of an eligible professional's Medicare Part B PFS charges must be comprised of the codes in the denominator of the measure to be eligible for an incentive or payment adjustment.
There is NO need to register to participate in this reporting program. Simply begin submitting the G-code on your claims appropriately, or, for eligible professionals attempting to quality for the incentive only, report the information required by the measure to a qualified registry, or submit the information required by the measure to CMS via a qualified EHR, if you satisfy the above requirements.
Other ways an eligible professional may avoid the 2012 payment adjustment are if the eligible professional:
• Is not a physician (MD, DO, or podiatrist), nurse practitioner, or physician assistant as of June 30, 2011, based on primary taxonomy code in the National Plan and Provider Enumeration System (NPPES);
• Does not have prescribing privileges and reports G-code G8644 (defined as not having prescribing privileges) at least one time on an eligible claim prior to June 30, 2011;
• Does not have at least 100 cases containing an encounter code in the measure denominator
• Does not meet the 10% denominator threshold
• Meets and reports a significant hardship exemption.
Avoiding e-prescription fine payment from Medicare
Do you want to avoid the 1% Medicare Part B payment adjustment on claims in 2012?
* Send at least 10 e-prescriptions for Medicare Part B patient visits which include one of the e-prescribing denominator codes*
AND
* Send your 10 claims to Medicare Part B with the denominator code* and code G8553 before 6/30/2011
OR
* Send one (1) claim to Medicare Part B with the denominator code and one of the Hardship codes before 6/30/2011
G8642: The eligible professional practices in a rural area without sufficient high speed internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act
G8643: The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act
G8644: the eligible professional does not have prescribing privileges
* Send at least 10 e-prescriptions for Medicare Part B patient visits which include one of the e-prescribing denominator codes*
AND
* Send your 10 claims to Medicare Part B with the denominator code* and code G8553 before 6/30/2011
OR
* Send one (1) claim to Medicare Part B with the denominator code and one of the Hardship codes before 6/30/2011
G8642: The eligible professional practices in a rural area without sufficient high speed internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act
G8643: The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act
G8644: the eligible professional does not have prescribing privileges
Denominator Code List for e-prescribing program
Eligible Denominator Codes
The applicable service codes for the electronic prescribing measure are:
The applicable service codes for the electronic prescribing measure are:
908xx 920xx 961xx 992xx 9930x 9931x 9932x 9934x 9935x G Codes 90801 92002 96150 99201 99304 99310 99324 99341 99350 G0101 90802 92004 96151 99202 99305 99315 99325 99342 G0108 90804 92012 96152 99203 99306 99316 99326 99343 G0109 90805 92014 99204 99307 99327 99344 90806 99205 99308 99345 90807 99211 99309 99347 90808 99212 99348 90809 99213 99349 90862 99214 99215
CPT code G8642, G8643, G8553
e-Prescribing Code
For successful e-prescribing events, the provider should report:
* G8553: At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.
Hardship Exemptions Codes
CMS recognizes that some providers may not be able to adopt e-prescribing for a number of reasons. The following three reasons are recognized by CMS to potentially avoid the negative adjustment on Medicare Part B PFS claims in 2012:
*G8642: The eligible professional practices in a rural area without sufficient high-speed Internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a) (5) (A) of the Social Security Act.
* G8643: The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under section 1848(a) (5) (A) of the Social Security Act.
* Alternative Reporting Option: When the eligible professional does not have prescribing privileges, report G8644 via claims. If this code is utilized, the eligible professional may not be considered for a payment adjustment.
For successful e-prescribing events, the provider should report:
* G8553: At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.
Hardship Exemptions Codes
CMS recognizes that some providers may not be able to adopt e-prescribing for a number of reasons. The following three reasons are recognized by CMS to potentially avoid the negative adjustment on Medicare Part B PFS claims in 2012:
*G8642: The eligible professional practices in a rural area without sufficient high-speed Internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a) (5) (A) of the Social Security Act.
* G8643: The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under section 1848(a) (5) (A) of the Social Security Act.
* Alternative Reporting Option: When the eligible professional does not have prescribing privileges, report G8644 via claims. If this code is utilized, the eligible professional may not be considered for a payment adjustment.
AM I Eligible to get Medicare e-Prescribing Incentive for 2011? List of denominator codes
Are you an eligible professional attempting to earn the CMS e-Prescribing Incentive for 2011?
* Send 25 or more e-prescriptions for 25 Medicare Part B patient visits which include one of the e-prescribing denominator codes*
AND
* Send your 25 claims to Medicare Part B with the denominator code* and code G8553 by
12/31/2011
G8553: At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system
* Measure Denominator Codes:
Patient visit during the reporting period (CPT or HCPCS):
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
* Send 25 or more e-prescriptions for 25 Medicare Part B patient visits which include one of the e-prescribing denominator codes*
AND
* Send your 25 claims to Medicare Part B with the denominator code* and code G8553 by
12/31/2011
G8553: At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system
* Measure Denominator Codes:
Patient visit during the reporting period (CPT or HCPCS):
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109
Reporting method for E-prescription incentive Program - claim based , registry
Reporting Methods
The eRX Incentive can be reported to Medicare via two methods– claims-based reporting or through the Physician Quality Reporting System (PQRS – formerly PQRI) Registry:
* Claims-Based: Providers/billers add the applicable e-Prescribing code to their claims during 2011
o For 10 unique encounters before June 30, 2011 to avoid the potential penalty in 2012, AND
o For 15 more unique encounters before December 31, 2011 – for a total of 25 encounters during 2011 to potentially earn the 2011 incentive payment ofers the e-Prescribing Measure #125 prompt within our Claims-Based feature.
* Registry: this is pursuing qualification to include the e-prescribing measure in eCW PQRS Registry reporting for 2011. This process with CMS will not be complete until late Summer 2011, and CMS plans to publish the list of qualified Registries sometime in the fall. Since it will not be known if eClinicalWorks has qualified until later in the year, we strongly suggest that clients submit the e-prescribing measures on claims – especially since they must submit those first 10 on claims before June 30, 2011 to avoid the 2012 penalty.
The eRX Incentive can be reported to Medicare via two methods– claims-based reporting or through the Physician Quality Reporting System (PQRS – formerly PQRI) Registry:
* Claims-Based: Providers/billers add the applicable e-Prescribing code to their claims during 2011
o For 10 unique encounters before June 30, 2011 to avoid the potential penalty in 2012, AND
o For 15 more unique encounters before December 31, 2011 – for a total of 25 encounters during 2011 to potentially earn the 2011 incentive payment ofers the e-Prescribing Measure #125 prompt within our Claims-Based feature.
* Registry: this is pursuing qualification to include the e-prescribing measure in eCW PQRS Registry reporting for 2011. This process with CMS will not be complete until late Summer 2011, and CMS plans to publish the list of qualified Registries sometime in the fall. Since it will not be known if eClinicalWorks has qualified until later in the year, we strongly suggest that clients submit the e-prescribing measures on claims – especially since they must submit those first 10 on claims before June 30, 2011 to avoid the 2012 penalty.
E-prescription Medicare Incentive Payments -Key Points
Key Points
1. All providers who submit Medicare Part B Fee for Service Claims will be subject to a payment adjustment in 2012 UNLESS they report 10 e-prescribing events BEFORE June 30, 2011.
2. These 10 e-prescribing events must be reported via claims. They cannot be reported via the Physician Quality Reporting System (PQRS) or any other Medicare reporting system.
3. The only exception is if the provider qualifies for a hardship exemption – see Hardship Exemptions section below for the three hardship reasons.
4. All providers who submit Medicare Part B Fee for Service Claims will be subject to a payment adjustment in 2013 UNLESS they report 25 e-prescribing events BEFORE December 31, 2011.
The Centers for Medicare and Medicaid Services (CMS) are again sponsoring an incentive program to encourage providers to adopt full electronic prescribing capabilities, often described as Informed e-Prescribing. CMS will provide an incentive payment equal to 1% of Medicare Part B Fee for Service (FFS) claims for 2011 for providers who successfully adopt and report on this adoption. Additionally, Medicare has instituted an adjustment (penalty) of 1% on 2012 Part B PFS claims, for providers who have not yet adopted e-prescribing. Lastly, a penalty of 1.5% will be imposed in 2013 for providers who have not yet adopted e-prescribing.
1. All providers who submit Medicare Part B Fee for Service Claims will be subject to a payment adjustment in 2012 UNLESS they report 10 e-prescribing events BEFORE June 30, 2011.
2. These 10 e-prescribing events must be reported via claims. They cannot be reported via the Physician Quality Reporting System (PQRS) or any other Medicare reporting system.
3. The only exception is if the provider qualifies for a hardship exemption – see Hardship Exemptions section below for the three hardship reasons.
4. All providers who submit Medicare Part B Fee for Service Claims will be subject to a payment adjustment in 2013 UNLESS they report 25 e-prescribing events BEFORE December 31, 2011.
The Centers for Medicare and Medicaid Services (CMS) are again sponsoring an incentive program to encourage providers to adopt full electronic prescribing capabilities, often described as Informed e-Prescribing. CMS will provide an incentive payment equal to 1% of Medicare Part B Fee for Service (FFS) claims for 2011 for providers who successfully adopt and report on this adoption. Additionally, Medicare has instituted an adjustment (penalty) of 1% on 2012 Part B PFS claims, for providers who have not yet adopted e-prescribing. Lastly, a penalty of 1.5% will be imposed in 2013 for providers who have not yet adopted e-prescribing.
Requirements of E-prescribing incentive program
2011 E-Prescribing Incentive Program Requirements
CMS proposes to continue with the 2010 e-prescribing reporting requirement in 2011, which is to require eligible physicians to report on 25 services in 2011 involving electronic prescriptions in order to qualify for incentives. We appreciate CMS’ consideration of the AMA’s recommendation to minimize the e-prescribing reporting burden. We support CMS’ proposal that for 2011, eligible physicians report the e-prescribing G-code, G8553, only twenty-five times for applicable Medicare office visit and service codes in order to receive the e-prescribing incentive, which totals up to one percent of their Medicare allowable charges. In addition, the AMA agrees with CMS’ proposal to allow several mechanisms for physicians to submit e-prescribing information (e.g., vis a vis Medicare Part B claims, a qualified registry, or a qualified EHR product). Please also refer to our comments on requirements for qualified registries and the EHR reporting option under the PQRI section. We remain committed to working with CMS to pursue significant outreach to the physician community on the 2011 e-prescribing incentive program details.
2012 and 2013 E-Prescribing Penalty Programs
CMS has also proposed criteria for applying penalties in 2012 and 2013 for physicians and group practices that are deemed to be unsuccessful e-prescribers. The law that established the Medicare e-prescribing incentive program, the “Medicare Improvements for Patients and Providers Act of 2008” (MIPPA) (P.L. 110-275), requires a penalty phase for eligible physicians who do not e-prescribe during 2012 through 2014. According to MIPPA, physicians who are eligible but choose not to participate in the 2012 or 2013 Medicare e-prescribing incentive program and do not qualify for a hardship exemption would be subject to a one percent Medicare payment reduction based on their Medicare Part B allowed charges (1.5 percent in 2013). MIPPA does provide the Secretary of HHS with the authority to exempt eligible physicians from penalties for hardship reasons. CMS’ proposal is to levy financial penalties in 2012 and 2013 against physicians who fail to report the e-prescribing measure ten times during the first six months in 2011.
We strongly oppose CMS’ proposal to levy financial penalties in 2012 and 2013 against physicians who fail to report the e-prescribing measure during the first six months in 2011 (January 1, 2011 through June 30, 2011). CMS’ proposal conflicts with the intent of the law, which clearly delays penalties until 2012. The law states that the penalty would apply “with respect to covered professional services furnished by an eligible professional during 2012, 2013, or 2014.” Applying penalties to services rendered in 2011 conflicts with the above-mentioned language in the law. Congress clearly intended to provide CMS as much flexibility as possible to come up with a penalty program that is fair and reasonable. Reviewing e-prescribing activity during the first six months of 2011 in order to assess penalties in 2012 and 2013 is an imbalanced approach. CMS has yet to produce the 2009 e-prescribing data and to address whether there were any problems in e-prescribing reporting. Inflicting financial penalties in 2012 and 2013 based on 2011 e-prescribing activity without fully assessing the 2009 and 2010 program, including adoption and use rates, is unfair and unreasonable. We insist that CMS revise the 2012 and 2013 penalty criteria. Financial penalties should only be levied in 2012 and 2013 against Medicare eligible physicians who fail to qualify for an exemption and fail to e-prescribe ten permissible prescriptions by the end of 2012 or by the end of 2013. Unlike CMS’ proposal, our recommended approach is entirely consistent with the intent of the law.
CMS proposes two narrow categories for exempting eligible physicians from the e-prescribing penalty: eligible physician/group practice practices in rural area with limited high speed internet access; and eligible physician/group practice practices in an area with limited available pharmacies for e-prescribing. Although we support these exception categories, we strongly recommend that CMS add more exception categories.
CMS has failed to consider that many physicians postponed purchasing an e-prescribing software or application in order to take advantage of Medicare and Medicaid EHR incentives prescribed by the “American Recovery and Reinvestment Act” (ARRA) (P.L. 111-5). ARRA was signed into law in February 2009, less than eight months after the enactment of the e-prescribing incentive program, and authorizes incentives for up to five years to eligible physicians who demonstrate meaningful use of an EHR, that includes e-prescribing functionality. The Medicare e-prescribing incentive program and the Medicare EHR incentive program are at odds with each other. According to ARRA, physicians who choose to participate in the Medicare EHR incentive program can not participate in the Medicare e-prescribing incentive program simultaneously. In order to avoid an e-prescribing penalty, physicians would have to invest in a stand alone e-prescribing application along with a certified EHR system which would pose a significant financial, administrative hardship on them. Physicians should therefore, not be penalized because it makes more economic, practical sense to choose to participate in the EHR incentive program and for investing in an electronic system that performs more than just e-prescribing.
There is also flexibility in the EHR incentive program on the start date for EHR use. Physicians are eligible for incentives even if they wait until 2014 to take part in the EHR incentive program. Another critical factor that needs to be considered is the fact that most physician practices are small and many of these physicians, like the rest of the population, are reaching retirement age in large numbers. It will be economically burdensome for physicians who intend to retire in the next five years to install and utilize an e-prescribing system as they continue to face looming Medicare payment cuts. We are also concerned that many of these physicians may decide to close their Medicare panels or opt out of Medicare to avoid penalties during the end stage of their clinical careers, which would adversely affect access to care for our nation’s elderly and disabled. Physicians who are currently eligible for Social Security retirement benefits or will be eligible for Social Security retirement benefits by 2014 should have the opportunity to apply for an exemption. In general, a person must be at least age 62 to start collecting Social Security retirement benefits. Another exception category should be for physicians who prescribe controlled substances so that they have adequate time to purchase and install Drug Enforcement Administration (DEA) compliant e-prescribing applications, which are not yet readily available.
In addition to CMS’ above-mentioned proposed exemption categories, we strongly recommend that CMS exempt other categories of eligible physicians from the 2012 and 2013 penalties, including: physicians who plan on participating in the EHR incentive program beginning in 2012, 2013, or 2014; physicians who are currently eligible for Social Security benefits or will be eligible for Social Security benefits by 2014; and physicians who prescribe controlled substances and are working to comply with the new DEA e-prescribing requirements. A “G” code should be designated for each of these additional exception categories and physicians should be able to report the applicable “G” code(s) once in 2012 and in 2013 in order to be exempt from the 2012 and 2013 penalty programs.
CMS proposes to continue with the 2010 e-prescribing reporting requirement in 2011, which is to require eligible physicians to report on 25 services in 2011 involving electronic prescriptions in order to qualify for incentives. We appreciate CMS’ consideration of the AMA’s recommendation to minimize the e-prescribing reporting burden. We support CMS’ proposal that for 2011, eligible physicians report the e-prescribing G-code, G8553, only twenty-five times for applicable Medicare office visit and service codes in order to receive the e-prescribing incentive, which totals up to one percent of their Medicare allowable charges. In addition, the AMA agrees with CMS’ proposal to allow several mechanisms for physicians to submit e-prescribing information (e.g., vis a vis Medicare Part B claims, a qualified registry, or a qualified EHR product). Please also refer to our comments on requirements for qualified registries and the EHR reporting option under the PQRI section. We remain committed to working with CMS to pursue significant outreach to the physician community on the 2011 e-prescribing incentive program details.
2012 and 2013 E-Prescribing Penalty Programs
CMS has also proposed criteria for applying penalties in 2012 and 2013 for physicians and group practices that are deemed to be unsuccessful e-prescribers. The law that established the Medicare e-prescribing incentive program, the “Medicare Improvements for Patients and Providers Act of 2008” (MIPPA) (P.L. 110-275), requires a penalty phase for eligible physicians who do not e-prescribe during 2012 through 2014. According to MIPPA, physicians who are eligible but choose not to participate in the 2012 or 2013 Medicare e-prescribing incentive program and do not qualify for a hardship exemption would be subject to a one percent Medicare payment reduction based on their Medicare Part B allowed charges (1.5 percent in 2013). MIPPA does provide the Secretary of HHS with the authority to exempt eligible physicians from penalties for hardship reasons. CMS’ proposal is to levy financial penalties in 2012 and 2013 against physicians who fail to report the e-prescribing measure ten times during the first six months in 2011.
We strongly oppose CMS’ proposal to levy financial penalties in 2012 and 2013 against physicians who fail to report the e-prescribing measure during the first six months in 2011 (January 1, 2011 through June 30, 2011). CMS’ proposal conflicts with the intent of the law, which clearly delays penalties until 2012. The law states that the penalty would apply “with respect to covered professional services furnished by an eligible professional during 2012, 2013, or 2014.” Applying penalties to services rendered in 2011 conflicts with the above-mentioned language in the law. Congress clearly intended to provide CMS as much flexibility as possible to come up with a penalty program that is fair and reasonable. Reviewing e-prescribing activity during the first six months of 2011 in order to assess penalties in 2012 and 2013 is an imbalanced approach. CMS has yet to produce the 2009 e-prescribing data and to address whether there were any problems in e-prescribing reporting. Inflicting financial penalties in 2012 and 2013 based on 2011 e-prescribing activity without fully assessing the 2009 and 2010 program, including adoption and use rates, is unfair and unreasonable. We insist that CMS revise the 2012 and 2013 penalty criteria. Financial penalties should only be levied in 2012 and 2013 against Medicare eligible physicians who fail to qualify for an exemption and fail to e-prescribe ten permissible prescriptions by the end of 2012 or by the end of 2013. Unlike CMS’ proposal, our recommended approach is entirely consistent with the intent of the law.
CMS proposes two narrow categories for exempting eligible physicians from the e-prescribing penalty: eligible physician/group practice practices in rural area with limited high speed internet access; and eligible physician/group practice practices in an area with limited available pharmacies for e-prescribing. Although we support these exception categories, we strongly recommend that CMS add more exception categories.
CMS has failed to consider that many physicians postponed purchasing an e-prescribing software or application in order to take advantage of Medicare and Medicaid EHR incentives prescribed by the “American Recovery and Reinvestment Act” (ARRA) (P.L. 111-5). ARRA was signed into law in February 2009, less than eight months after the enactment of the e-prescribing incentive program, and authorizes incentives for up to five years to eligible physicians who demonstrate meaningful use of an EHR, that includes e-prescribing functionality. The Medicare e-prescribing incentive program and the Medicare EHR incentive program are at odds with each other. According to ARRA, physicians who choose to participate in the Medicare EHR incentive program can not participate in the Medicare e-prescribing incentive program simultaneously. In order to avoid an e-prescribing penalty, physicians would have to invest in a stand alone e-prescribing application along with a certified EHR system which would pose a significant financial, administrative hardship on them. Physicians should therefore, not be penalized because it makes more economic, practical sense to choose to participate in the EHR incentive program and for investing in an electronic system that performs more than just e-prescribing.
There is also flexibility in the EHR incentive program on the start date for EHR use. Physicians are eligible for incentives even if they wait until 2014 to take part in the EHR incentive program. Another critical factor that needs to be considered is the fact that most physician practices are small and many of these physicians, like the rest of the population, are reaching retirement age in large numbers. It will be economically burdensome for physicians who intend to retire in the next five years to install and utilize an e-prescribing system as they continue to face looming Medicare payment cuts. We are also concerned that many of these physicians may decide to close their Medicare panels or opt out of Medicare to avoid penalties during the end stage of their clinical careers, which would adversely affect access to care for our nation’s elderly and disabled. Physicians who are currently eligible for Social Security retirement benefits or will be eligible for Social Security retirement benefits by 2014 should have the opportunity to apply for an exemption. In general, a person must be at least age 62 to start collecting Social Security retirement benefits. Another exception category should be for physicians who prescribe controlled substances so that they have adequate time to purchase and install Drug Enforcement Administration (DEA) compliant e-prescribing applications, which are not yet readily available.
In addition to CMS’ above-mentioned proposed exemption categories, we strongly recommend that CMS exempt other categories of eligible physicians from the 2012 and 2013 penalties, including: physicians who plan on participating in the EHR incentive program beginning in 2012, 2013, or 2014; physicians who are currently eligible for Social Security benefits or will be eligible for Social Security benefits by 2014; and physicians who prescribe controlled substances and are working to comply with the new DEA e-prescribing requirements. A “G” code should be designated for each of these additional exception categories and physicians should be able to report the applicable “G” code(s) once in 2012 and in 2013 in order to be exempt from the 2012 and 2013 penalty programs.
E-Prescribing incentive program feedback review
Feedback Report on E-Prescribing Incentive Program and Appeals Process
We also remain concerned that despite the AMA’s numerous requests, CMS has not yet produced 2009 e-prescribing data or issued 2009 incentive payments. Assessing the 2009 e-prescribing data is essential for evaluating the success of the incentive program and for applying lessons learned to the e-prescribing as well as other related programs like the Medicare and Medicaid EHR incentive programs. We urge CMS to provide feedback reports as soon as practicable so that physicians have timely, actionable information on potential problems in their e-prescribing reporting.
We also urge CMS to include a mechanism for physicians to appeal any aspect of the e-prescribing incentive program (e.g., payments or eligibility). We believe it is critical that physicians have an opportunity to appeal decisions that affect their ability to get incentives. Given the pitfalls experienced with the Medicare PQRI, we strongly recommend that a timely feedback loop and appeals process be built into the program to allow physicians to address reporting problems and appeal decisions that affect their eligibility to take part in the program or that affect their ability to get incentives.
Reporting of Successful E-Prescribers
In accordance with the law, CMS plans to publicly report the names of 2011 successful e-prescribers on the CMS website. We urge CMS to take appropriate measures to ensure the accuracy of the list of successful e-prescribers and to provide the appropriate disclaimers for the website listing. CMS should consider delaying the posting until CMS is able to pursue an educational campaign and is able to post appropriate disclaimers along with the list of successful e-prescribers. Physicians and patients should understand: the purpose for the posting given that this incentive program just started in 2009; that adjustments to the program have been made since 2009; and that the law does not allow physicians to participate in this program and others (e.g., Medicare EHR incentive program) simultaneously so many physicians have to select one incentive program over another. Please also refer to our comments on public reporting under the PQRI section.
We also remain concerned that despite the AMA’s numerous requests, CMS has not yet produced 2009 e-prescribing data or issued 2009 incentive payments. Assessing the 2009 e-prescribing data is essential for evaluating the success of the incentive program and for applying lessons learned to the e-prescribing as well as other related programs like the Medicare and Medicaid EHR incentive programs. We urge CMS to provide feedback reports as soon as practicable so that physicians have timely, actionable information on potential problems in their e-prescribing reporting.
We also urge CMS to include a mechanism for physicians to appeal any aspect of the e-prescribing incentive program (e.g., payments or eligibility). We believe it is critical that physicians have an opportunity to appeal decisions that affect their ability to get incentives. Given the pitfalls experienced with the Medicare PQRI, we strongly recommend that a timely feedback loop and appeals process be built into the program to allow physicians to address reporting problems and appeal decisions that affect their eligibility to take part in the program or that affect their ability to get incentives.
Reporting of Successful E-Prescribers
In accordance with the law, CMS plans to publicly report the names of 2011 successful e-prescribers on the CMS website. We urge CMS to take appropriate measures to ensure the accuracy of the list of successful e-prescribers and to provide the appropriate disclaimers for the website listing. CMS should consider delaying the posting until CMS is able to pursue an educational campaign and is able to post appropriate disclaimers along with the list of successful e-prescribers. Physicians and patients should understand: the purpose for the posting given that this incentive program just started in 2009; that adjustments to the program have been made since 2009; and that the law does not allow physicians to participate in this program and others (e.g., Medicare EHR incentive program) simultaneously so many physicians have to select one incentive program over another. Please also refer to our comments on public reporting under the PQRI section.
How to Coding - E- prescribing with example
Medicare E-prescribing Bonus Payment – Coding Scenario Examples
Example for G8443; All Medications Prescribed Electronically
Mr. Johnson sees Dr. Smith regularly for treatment of his hypertension and hyperlipidemia. Dr. Smith e-prescribes the renewal of Mr. Johnson’s medication. Dr. Smith bills CPT code 99214 for the established patient office visit and reports the HCPCS code G8443 to indicate that all prescriptions generated during the visit were electronically prescribed. Dr. Smith lists ICD-9 code 401.1 to indicate Mr. Johnson’s benign hypertension as the primary reason for the encounter.
Example for G8445, No Medications Prescribed
Mrs. Jones, who is new to Medicare, comes to see Dr. Smith because of her acute, mild respiratory symptoms. Dr. Smith determines that Mrs. Jones has a cold and recommends an over the counter medication. Dr. Smith bills CPT code 99202 for the new patient office visit and reports the HCPCS code G8445 to indicate that there were no prescriptions associated with the visit. Dr. Smith lists ICD-9 code 460, acute nasopharyngitis, as the reason for the encounter.
Example for G8446, One or More of Medications Not Prescribed Electronically
Mrs. Green, who regularly visits Dr. Smith for multiple chronic conditions, sees Dr.Smith for extreme pain associated with her severe arthritis that is compounded by her osteoporosis. Dr. Smith prescribes a controlled substance, which cannot be prescribed electronically, for her pain in addition to renewing other prescriptions. Dr. Smith bills CPT code 99215 for the established patient office visit and reports the HCPCS code G8446 to indicate that one or more of medications were not e-prescribed. Dr. Smith lists ICD-9 code 715.09 to indicate Mrs. Green’s generalized osteoarthritis in multiple sites is the primary reason for the encounter.
Example for G8443; All Medications Prescribed Electronically
Mr. Johnson sees Dr. Smith regularly for treatment of his hypertension and hyperlipidemia. Dr. Smith e-prescribes the renewal of Mr. Johnson’s medication. Dr. Smith bills CPT code 99214 for the established patient office visit and reports the HCPCS code G8443 to indicate that all prescriptions generated during the visit were electronically prescribed. Dr. Smith lists ICD-9 code 401.1 to indicate Mr. Johnson’s benign hypertension as the primary reason for the encounter.
Example for G8445, No Medications Prescribed
Mrs. Jones, who is new to Medicare, comes to see Dr. Smith because of her acute, mild respiratory symptoms. Dr. Smith determines that Mrs. Jones has a cold and recommends an over the counter medication. Dr. Smith bills CPT code 99202 for the new patient office visit and reports the HCPCS code G8445 to indicate that there were no prescriptions associated with the visit. Dr. Smith lists ICD-9 code 460, acute nasopharyngitis, as the reason for the encounter.
Example for G8446, One or More of Medications Not Prescribed Electronically
Mrs. Green, who regularly visits Dr. Smith for multiple chronic conditions, sees Dr.Smith for extreme pain associated with her severe arthritis that is compounded by her osteoporosis. Dr. Smith prescribes a controlled substance, which cannot be prescribed electronically, for her pain in addition to renewing other prescriptions. Dr. Smith bills CPT code 99215 for the established patient office visit and reports the HCPCS code G8446 to indicate that one or more of medications were not e-prescribed. Dr. Smith lists ICD-9 code 715.09 to indicate Mrs. Green’s generalized osteoarthritis in multiple sites is the primary reason for the encounter.
How to Report the E-prescribing Incentive Program Measure
To obtain the incentive in 2009, you have to report on the e-prescribing quality
measure for 50% of applicable cases. The e-prescribing measure has two basic elements: (1) a reporting denominator consisting of a specified set of service codes that defines the circumstances when the measure is reportable; and (2) a reporting numerator consisting of a set of specific “G” -codes, one of which must be reported for successful reporting.
When you have an applicable case (defined by engaging in one of the service codes listed in Step 1 below for a Medicare Part B Fee-For-Service beneficiary), you report on the e-prescribing measure with two steps:
Step 1. Bill on one of the following service denominator codes:
| 90801 | 92004 | 99201 | 99215 |
| 90802 | 92012 | 99202 | 99241 |
| 90804 | 92014 | 99203 | 99242 |
| 90805 | 96150 | 99204 | 99243 |
| 90806 | 96151 | 99205 | 99244 |
| 90807 | 96152 | 99211 | 99245 |
| 90808 | 99212 | G0101 | |
| 90809 | 99213 | G0108 | |
| 92002 | 99214 | G0109 |
*Codes in bold typically billed by internists.
Step 2. Report one of the three G-codes listed below on more than 50% of applicable
cases for the numerator. All three codes (even the code for not generating prescriptions)
count toward the e-prescribing incentive. One of the G codes must be reported on the
same claim as the denominator billing code.
E-prescribing Incentive Program Quick Reference: G -Codes
| If You... | Report |
| Used a qualified e-prescribing system for all of the prescriptions | G8443 |
| Had a qualified e-prescribing system, but didn’t generate any prescriptions during this encounter | G8445 |
| Had a qualified e-prescribing system, but could not electronically submit one or more of the generated prescriptions because: • The prescription was for narcotics or other controlled substances. • State or Federal law required you to phone in or print the prescriptions. • The patient asked that you phone in or print the prescriptions. • The pharmacy system was unable to receive an electronic transmission. | G8446 |
*** Work Flow Suggestion—Add the three e-prescribing measure numerator G-Codes to your superbill.
How much provider will get for E- prescribing
E- Prescribing - Incentive qualified
Medicare Incentive for “Qualified eRx”:
According to the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008, any provider who meets an annual threshold of e–prescribing/ patients volume will get incentive payments from Medicare which will start at 2 percent for 2009 and 2010, and then drop to 1 percent in 2011 and 2012 and subsequently fall to 0.5 percent in 2013.
However, those providers who are not adopting E-prescribing, their Medicare reimbursements will decrease by 1 percent in 2012, 1.5 percent in 2013 and 2 percent in 2014 and later.
Those providers who are adopting e-prescribing early will be eligible for the following Medicare reimbursements:
Providers are adopting e-prescribing by year Receive Medicare reimbursements ( %)
2009 2
2010 2
2011 1
2012 1
2013 0.5
Those providers who are not adopting e-prescribing by 2012, their Medicare reimbursements will decrease as follows:
Providers are not adopting e-prescribing by year Medicare reimbursements decrease by (%)
2012 1.0
2013 1.5
2014 2.00
2015 and subsequent year.
A “Qualified Rx” must be competent enough to performing all of the following functions.
Medicare Incentive for “Qualified eRx”:
According to the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008, any provider who meets an annual threshold of e–prescribing/ patients volume will get incentive payments from Medicare which will start at 2 percent for 2009 and 2010, and then drop to 1 percent in 2011 and 2012 and subsequently fall to 0.5 percent in 2013.
However, those providers who are not adopting E-prescribing, their Medicare reimbursements will decrease by 1 percent in 2012, 1.5 percent in 2013 and 2 percent in 2014 and later.
Those providers who are adopting e-prescribing early will be eligible for the following Medicare reimbursements:
Providers are adopting e-prescribing by year Receive Medicare reimbursements ( %)
2009 2
2010 2
2011 1
2012 1
2013 0.5
Those providers who are not adopting e-prescribing by 2012, their Medicare reimbursements will decrease as follows:
Providers are not adopting e-prescribing by year Medicare reimbursements decrease by (%)
2012 1.0
2013 1.5
2014 2.00
2015 and subsequent year.
A “Qualified Rx” must be competent enough to performing all of the following functions.
- Generate a complete active medication list
- Select medications, print prescriptions, electronically transmit prescriptions, and conduct all time alerts(safety checks include: automated prompts that offer information on the drug being prescribed, potential inappropriate dose or route of administration, drug-drug interactions, allergy concerns, or warnings or cautions)
- Provide information on lower-cost, therapeutically appropriate alternatives (if any)
- Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient’s drug plan (if available)
E - prescribing some standard date limits.
E-Prescribing
A prescriber's ability to electronically send an accurate, error-free and understandable prescription directly to a pharmacy from the point-of-care - is an important element in improving the quality of patient care. The inclusion of electronic prescribing in the Medicare Modernization Act (MMA) of 2003 gave momentum to the movement, and the July 2006 Institute of Medicine report on the role of e-prescribing in reducing medication errors received widespread publicity, helping to build awareness of e-prescribing's role in enhancing patient safety. Adopting the standards to facilitate e-prescribing is one of the key action items in the governments plan to expedite the adoption of electronic medical records and build a national electronic health information infrastructure in theUnited States
The MMA created a new voluntary prescription drug benefit under Medicare Part D. Although e-prescribing will be optional for physicians and pharmacies, Medicare Part D will require drug plans participating in the new prescription benefit to support electronic prescribing.
Standards Timeline
A prescriber's ability to electronically send an accurate, error-free and understandable prescription directly to a pharmacy from the point-of-care - is an important element in improving the quality of patient care. The inclusion of electronic prescribing in the Medicare Modernization Act (MMA) of 2003 gave momentum to the movement, and the July 2006 Institute of Medicine report on the role of e-prescribing in reducing medication errors received widespread publicity, helping to build awareness of e-prescribing's role in enhancing patient safety. Adopting the standards to facilitate e-prescribing is one of the key action items in the governments plan to expedite the adoption of electronic medical records and build a national electronic health information infrastructure in the
The MMA created a new voluntary prescription drug benefit under Medicare Part D. Although e-prescribing will be optional for physicians and pharmacies, Medicare Part D will require drug plans participating in the new prescription benefit to support electronic prescribing.
Standards Timeline
- On November 7, 2005, CMS published the first set of adopted standards known as the foundation standards. The foundation standards became effective on January 1, 2006. These standards apply to all electronic prescribing done under Part D of the MMA.
- MMA required CMS to implement pilot projects to test additional standards. These additional standards were pilot tested in 2006.
- On June 23, 2006 CMS published an interim final rule with comment to adopt NCPDP SCRIPT Standard version 8.1 on a voluntary basis to be used for e-prescribing.
- The results of the pilot test were announced in a report to Congress in April 2007 and were the basis for an NPRM proposing additional standards that was published on November 16, 2007.
- The final e-prescribing rule was published at the Federal Register on April 7, 2008. In this final rule CMS adopted 3 additional standards for use in e-prescribing under part D.
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