Nothing like a snappy headline to grab your attention, no? As sensational as it may sound, it is actually true in a very unique circumstance. If you have never demonstrated meaningful use, but intend to do so in 2013, read on. Everyone else gets a rain check today and can pick up the blog again next week.
Revisiting the carrot and the stick
CMS has created a pattern that warrants our attention. Within the CMS incentive programs that are frequent topics of this blog, one typically finds a positive financial incentive (the carrot) early in the program and a negative financial incentive (the stick) late in the game. Nothing surprising here, but to quote Daniel Pink, “Carrots and Sticks are so last century.” I digress, but the point is CMS would prefer not to levy those negative financial incentives. Time and again, with several of the programs they have made it much easier to avoid the penalty than to win the incentive.
Take PQRS for example. This year is the payment adjustment reporting period for 2015. Basically this means CMS will survey provider behavior this year to determine whom to penalize in 2015. Granted, you can avoid the penalty by successfully submitting PQRS data in 2013. But if you send quality data for a single patient, that is you made the effort to participate in 2013, CMS promises no penalty will be levied in 2015.
One simple move allows you to avoid the eRx penalty
In this same vein, avoiding the eRx penalty is much easier than capturing the eRx incentive. As you may recall, the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) requires CMS to subject providers who are not successful electronic prescribers to a “payment adjustment”. For 2013, that 1.5% payment adjustment basically translates into the provider receiving 98.5% of the Medicare Physician Fee Schedule for ALL Medicare Part B covered professional services delivered during 2013. Based on publically available information from the 2010 PQRS program, for the average nephrologist this penalty equates to just north of $4,500. Of course this will vary from provider to provider, but this is not an insignificant amount of money and it is basically paid after everyone else in your practice is paid.
So this brings us back to our headline today. If in fact you have not demonstrated meaningful use in the past, but intend to do so this year, one of the first steps is to register your intent to participate. If you do so before January 31, 2013, CMS will recognize your intent to demonstrate meaningful use AND CMS will exclude you from the 2013 eRx penalty. One difference between simply registering for meaningful use and avoiding the 2013 eRx penalty is that when you register for meaningful use, entering the certified EHRs product number is optional. From a meaningful use perspective, CMS will permit you to enter the product number at any point prior to attestation. If you expect the act of registering to prevent the 2013 eRx penalty, you must enter the certified EHR’s product number when you register for the EHR Incentive Program.
Ten days is not a lot of time, but the registration process takes only a few minutes. Will 2013 be your first year for meaningful use? If you find yourself in this position, take a few minutes and register before the January 31 deadline. You will be happy you did.
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