The 2014 eRx Penalty: It’s Not Too Late

Regular readers of this blog may be delighted to learn this could be my last post related to the CMS eRx incentive program. Why? Next year is the last year the program will exist, and in 2014 there will not be a financial bonus, only a penalty. Time is running out for those of you who have not yet done what needs to be done to avoid next year’s 2.0% eRx payment adjustment. I cannot think of a better way to bid adieu to this program than to conjure up a favorite tune from my youth.

 

Ticking away the moments that make up a dull day

 

In reality there is nothing dull about your days, as I am sure you are busy taking care of patients, demonstrating meaningful use and preparing for next year’s ICD-10 transition. But buried at the bottom of this pile of work should be a simple checklist with the actions you can take to avoid next year’s two percent eRx haircut. If not, let’s review those opportunities.

 

Plans that either come to naught or half a page of scribbled lines

 

If you find yourself in this boat, ask yourself if any of the following apply to you or your providers (including your advanced practioners):

• You demonstrated meaningful use in 2012.
• You attested for your first year of meaningful use in 2013 prior to June 30, 2013.
• You have never attested for meaningful use, but you have registered your intent to do so this year before June 30. (Don’t forget to include the EHR certification number when you register.)
• You successfully participated in the 2012 eRx program (of course, you will not know you were successful until you receive the incentive later this fall).
• You put the eRx G-code on any 10 Medicare Part B claims for services rendered between January 1 and June 30, 2013, that involved an encounter during which you electronically prescribed.
• You will have fewer than 100 denominator-eligible encounters with Medicare Part B beneficiaries between January 1 and June 30, 2013 (a common way out for nephrology advanced practioners).

There are some additional ways to avoid the 2014 penalty, but they do not commonly apply to nephrologists.

 

No one told you when to run, you missed the starting gun

 

Suppose you find yourself in mid-June (say, June 17) without having satisfied one of the items mentioned above. You have two more weeks to take action! Note the deadline for several items above is June 30, 2010. Your actions in the next ten business days could mean the difference between facing the 2.0 percent 2014 penalty and escaping this unpleasant haircut.

 

Waiting for someone or something to show you the way

 

If you haven’t done what it takes to avoid the 2014 eRx penalty, the simplest thing to do is to put that G-code (G8553) on 10 appropriate Medicare Part B claims before the last day of this month. CMS has actually made this relatively easy. Unlike the process involved with qualifying for the bonus, avoiding the penalty does not require the electronic prescribing to occur during specific visits. If you use your qualified e-prescribing solution to generate and transmit a prescription during an encounter with a Medicare Part B patient, it does not matter where the encounter occurred (office, hospital, dialysis center or home). Again ANY 10 encounters are fair game for avoiding the penalty. CMS just wants to know that you are prescribing electronically.

 

As the CMS eRx incentive program rides off into the sunset, I can almost hear Gilmour et al belting out Roger Waters’ classic lyrics “You run and you run to catch up with the sun, but it’s sinking, racing around to come up behind you again.” So remember, if you are still subject to next year’s penalty, you still have Time.