The CMS e-prescribing program has been in place for almost 2 years. During that time the national utilization of e-Rx technology has increased dramatically. Surescripts tracks these figures and last month announced the number of physicians e-prescribing nationwide now exceeds 200,000. Surescripts provides a slick tool on their website that displays statistics about the penetration of e-Rx in your state.
The CMS e-Rx incentive initiative began as an individual PQRI measure in 2008. In 2009, CMS retired the e-Rx PQRI measure and created the standalone e-Rx incentive program in place today. Participation in 2009 was quite cumbersome requiring the addition of 1 of 3 G-codes to at least 50% of the provider’s Medicare part B office encounter claims. Another barrier to participation for the nephrologist was the requirement that at least 10% of their part B allowable charges for the year originated from work done in the office setting.
In 2010 (and proposed for 2011), the barriers to participation have been substantially reduced. Granted the 10% hurdle persists, however, if that hurdle is cleared, success now only requires the generation and transmission of an electronic prescription for 25 eligible patients over the course of the year. The incentive for 2010 is 2% of your part B allowable charges. Let me repeat that: If you clear the 10% hurdle and make CMS aware of the fact that you sent a script electronically during an office encounter for 25 Medicare part B patients during the course of 2010, CMS will pay you a 2% bonus on this year’s allowable part B charges. Based on published averages, we estimate this 2% bonus is worth $4,000 +/- $2,000 for the typical nephrologist. The incentive checks for the successful 2009 e-prescribers are in the mail and if you participated successfully last year, you should receive your incentive check by 10/22/2010. Sadly the incentive drops to 1% in 2011 and remains there for 2012 before declining to 0.5% in 2013, the last year an incentive will be paid.
So much for the carrots, what about the “stick”? The stick is an adjustment in the Medicare physician fee schedule (PFS) for those providers not e-prescribing. This penalty is set to begin in 2012 with a 1% reduction in the Medicare PFS for those who do not e-prescribe. How will CMS determine who to apply the “stick” to? We received a hint in the recently published proposed rule for the 2011 Medicare PFS. Buried in this proposal on page 40208 of the Federal Register, Vol. 75, No. 133/Tuesday, July 13, 2010 is text that I paraphrase below:
We propose that the 2012 e-Rx penalty be applied to a physician unless one of the following applies;
1. The physician does not have at least 100 part B claims for office based services during the first 6 months of 2011.
2. The physician is a successful e-prescriber defined as letting CMS know they have successfully generated and transmitted electronic scripts during an office encounter for a part B beneficiary at least 10 times during the first 6 months of 2011.
3. A hardship exclusion exists to which the provider is willing to attest to consisting of:
a. The physician practices in a rural area with limited high speed internet access.
b. The physician practices in an area with limited available pharmacies for electronic prescribing.
Translation: If you see Medicare part B beneficiaries in the office at a rate that exceeds one patient per day you will face a 1% reduction in your 2012 Medicare PFS unless you e-prescribe in the first 6 months of next year or you are willing to attest to the fact that you practice Miles From Nowhere.
This of course is part of the proposed rule for the 2011 Medicare PFS and all of it is subject to modification in the final rule. However, I think it provides insight into the perspective CMS has related to the penalties involved with both the CMS pay for reporting programs (like e-Rx and PQRI) as well as with the EHR incentive program. The bottom line is this, nephrologists need to pay close attention to these financial “sticks” and to prepare for them appropriately. The final rule for the 2011 PFS should be out next month at which point we will revisit this issue. Next week I will explore the intersection of e-prescribing and the new CMS EHR incentive program.
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