Over the past few months we have explored a number of the meaningful use objectives within the CMS EHR incentive program. Here, I’d like to review two closely related stage 1 core objectives: e-prescribing and computerized physician order entry (CPOE).
E-prescribing
Electronic prescribing is one of the core measures for nephrologists electing to demonstrate meaningful use. (For a more detailed discussion on e-prescribing and meaningful use, see this earlier post.) Meeting this measure requires that at least 40% of the “permissible” prescriptions written by the provider during the reporting period are generated and transmitted electronically. The word permissible has a couple of important connotations for this measure. First, controlled medications (Schedule 2 and above) are excluded. The final rule’s publication preceded the DEA’s establishment of the electronic requirements for this group of medications; therefore, prescriptions for these meds are excluded from this measure. Second, this measure does not count prescriptions written for durable medical equipment or for diabetic supplies.
This is one of the few measures not tied to a specific patient encounter. That is to say, unlike the problem list measure which asks what percentage of the unique patients I encountered during the reporting period had a problem on their problem list, the denominator for the eRx measure is looking at all of the permissible prescriptions I write during the reporting period. The one caveat here is I should only count prescriptions written for patients whose records are maintained within the EHR. For example, if I discharge a patient from the hospital and they are not in my EHR, I should not count the discharge prescriptions in either the numerator or the denominator for this measure. One final point, providers who write fewer than 100 prescriptions during the reporting period are excluded from reporting this measure.
CPOE
The CPOE requirements have been the source of confusion for many nephrologists. In large part this is related to the context within which one typically hears the phrase “computerized physician order entry”—the hospital. In spite of a number of comments made during the comment period for the final rule, HHS elected to maintain the CPOE measure for both the hospital and the eligible professional arms of the EHR incentive program. But note that in a nod to the lack of existing infrastructure, the stage 1 requirement for CPOE is simply to enter the order in the ordering system. Actually transmitting the order is not required to satisfy this measure.
Other important points to consider:
• What is considered an order? All certified EHRs must have the capability to enter orders for medications, laboratory and radiology. However, the actual CPOE measure itself only looks at medication orders entered into the CPOE system, and the proxy for medication orders in an ambulatory system is the e-prescribing tool.
• What are the specifics for this measure? More than 30 percent of all unique patients seen by the nephrologist during the EHR reporting period who have at least one medication on their medication list must have at least one medication order entered using CPOE (remember the e-prescribing tool essentially serves as the CPOE proxy here). As with e-prescribing, providers who write fewer than 100 prescriptions during the reporting period are excluded from this measure.
What’s the bottom line for these two stage 1 core measures? Both require active utilization of the EHR’s e-prescribing tool. Use your prescription pads only for controlled medications and you will be in good shape with these two measures. The exclusion for these measures will be tough for the typical nephrologist to meet given the medical complexity of the patient population. Remember, if you elect to demonstrate meaningful use within the Medicare program you may not participate in the CMS e-prescribing incentive program (although you must submit the eRx G-code 10 times in the first 6 months of 2011 or face the penalty in 2012). The thresholds for both of these core measures are relatively low and with appropriate use of your eRx tool you can truly kill two birds with one stone.
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