Nephrology and eRx

A couple of weeks ago, CMS published a report that may be of interest to our readers. The report describes the experience with the CMS PQRS and eRx programs through 2011, and it provides a glimpse at some of the eRx penalty-related information for 2012. Let’s focus on the eRx data within the report.

 

The eRx nitty gritty

 

As a brief bit of background, recall the eRx program was separated from PQRS in 2009. The incentive peaked at 2% of the provider’s Medicare Part B book of business in 2009 and 2010. The incentive dropped to 1% in 2011 and it remained 1% for 2012. Also mentioned in this report is the 2012 eRx payment adjustment (penalty). 2012 was the first year a penalty was levied by one of the CMS incentive programs nephrologists face. The 2012 penalty was a 1% reduction in the Medicare Part B allowable for all services rendered in 2012.

 

Nephrologist participation ahead of the curve

 

One of the first things to note in this report is that a larger percentage of nephrologists have participated in the program compared with physicians in general. The bar chart below displays the percentage of eligible professionals participating in the CMS eRx program during the program’s first three years. The red bars labeled “MD/DO” represent all physicians. Note the substantial increase in participation between 2010 and 2011. This occurred in spite of a declining incentive (2% vs. 1%), and may reflect the impact of the looming 2012 penalty. Of additional interest, the 2011 figure represents 4,355 nephrologists among the 7,552 registered in the National Plan and Provider Enumeration System (NPPES) in 2011.

 

Percentage of Eligible Professionals Participating in the CMS eRx Program

 

Exceptions to the rule

 

What other nuggets of information are available in this report? I think there are several. A sizable percentage of nephrologists were not eligible to participate because less than 10% of their Part B allowable originated from codes that make up the denominator of the eRx measure (largely office-based E & M codes). In 2011, 14% of the nephrologists participating in the program failed to clear this 10% hurdle. In other words, although these 377 nephrologists successfully e-prescribed, they did not collect the 1% incentive because the vast majority of their Part B allowable originated outside the office venue of care. The same figure for the general population of physicians was 1.5% in 2011. This should not surprise us as a substantial proportion of the typical nephrologist’s Medicare Part B charges originate in other venues of care such as the hospital, the dialysis facility and, for some, the access center.

 

Participation pays off

 

Of additional interest is the amount of money this incentive created for the specialty in 2011. Almost 2,300 nephrologists collected about 7 million dollars for their participation in 2011. That is slightly more than in 2010, which is remarkable given the incentive percentage was only 1% in 2011 compared with 2% of the provider’s Part B allowable in 2010. This reflects the substantial increase in participation by nephrology between 2010 and 2011. Consistent with 2010, the 2011 figures suggest that for the nephrologists who particapted in 2011, the mean payout was just over $3,000. Stated another way, the annual Part B allowable for the typical nephrologist participating in 2011 was around $300,000.

 

Many still pay the penalty

 

One final note from this report relates to the 2012 eRx payment adjustment. This 1% Part B haircut was levied upon almost 136,000 Medicare providers last year. Sadly, 1,552 nephrologists were in this group. How did 20% of our specialty miss the boat here? A quick back-of-the-envelope calculation suggests our specialty left almost 5 million dollars on the table in 2011 because of this penalty. The larger 1.5% 2013 eRx penalty is in play now for some nephrologists. In 2014, the last year of the CMS eRx program, the penalty peaks at 2%. We have previously reviewed the CMS requirements to avoid the eRx penalty.

 

Three opportunities to avoid the 2014 penalty remain, and all require action prior to June 30, 2013:

1. Appropriately add the eRx G-code to any 10 Part B claims for services rendered if during that encounter a script was generated and transmitted electronically for the beneficiary.
2. Successfully attest to meaningful use for year 1 prior to June 30.
3. Register your intent to participate for the first time in the meaningful use program prior to June 30.

The bar is low for 2014. Let’s make sure our colleagues are not asleep at the wheel. Join the conversation and help us spread the word. The 2011 Reporting Experience contains additional information of interest to the practice of nephrology. Next week I’ll review the PQRS related content.