Last week I reviewed the stand-alone CMS e-prescribing incentive program. Today I want to explore e-prescribing in the context of the new CMS EHR incentive. E-Rx is one of the core meaningful use objectives. As such, all providers are expected to meet this objective unless they meet the criteria for an exclusion. The exclusion for e-Rx applies to physicians who write fewer than 100 prescriptions during the EHR reporting period. The reporting period for your first year of reporting is any continuous 90-day period within the calendar year. If you “write” more than 100 prescriptions during that time, you must report the e-Rx meaningful use objective.
From the final rule, this objective is defined as “Generate and transmit permissible prescriptions electronically (eRx).” Further explaining the word “permissible,” CMS goes on to state, “As discussed in the proposed rule the concept of only permissible prescriptions refers to the current restrictions established by the Department of Justice on electronic prescribing for controlled substances in Schedule II. (The substances in Schedule II can be found here.) Any prescription not subject to these restrictions would be permissible.” CMS goes on to point out that while the Department of Justice is working on standards for electronically prescribing controlled substances, those will be excluded from this calculation in stage 1.
The measure behind this objective contains a threshold and as such includes a denominator and a numerator. As with each meaningful use measure with a threshold, the denominator defines the patients or actions to be reported on and the numerator represents the actions taken. The denominator in this measure is the number of prescriptions written for drugs requiring a prescription in order to be dispensed (other than controlled substances) during the EHR reporting period. This measure is confined to actions that occur for patients whose “records are maintained using certified EHR technology.” For example, this excludes prescriptions “written” for new patients discharged from the hospital. The numerator for this fraction is defined as “The number of prescriptions in the denominator generated and transmitted electronically.” The threshold for this measure is 40%.
What does this imply for the practicing nephrologist? Simply stated, at least 40% of the permissible prescriptions “written” for patients whose records are maintained in the EHR must be sent via e-Rx. One of the challenges with this objective is the potential counting that may occur outside the EHR. For example, if you hand write a permissible prescription for one of your office patients, you must keep track of that and add it to the denominator prior to attesting that you have met this threshold. The threshold itself is low enough that most nephrologists should have no trouble clearing the bar; however, the administrative overhead of tracking and counting handwritten scripts could very quickly become burdensome. The solution from my perspective is to be diligent and always use your e-Rx application—even if you are simply entering the script, printing it, signing it and handing it to the patient. Most certified EHRs will add this action to the denominator for you (check with your vendor to be certain).
One final note
The CMS EHR incentive (aka Meaningful Use) and the stand-alone CMS e-Rx incentive program are mutually exclusive. In 2011 the successful participating nephrologist will either receive $18,000 for the Medicare EHR incentive program or 1% of their allowable Medicare part B charges for the e-Rx incentive program, but not both.
Leave a Reply