HIPAA & MEANINGFUL USE
Meaningful Use is all about helping patients. What does privacy and security have to do with it?
Meaningful Use is all about helping patients, but just as the law took steps to preserve the integrity, privacy, and security of paper records so we must protect the same information in electronic form. Responding to comments regarding the Meaningful Use final rule, CMS stated that “…maintaining privacy and security is crucial for every eligible provider (EP), eligible hospital or Critical Access Hospital (CAH) that uses certified EHR technology.” Citation: Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Final Rule. Federal Register 75:144 (28 July 2010) p. 44369.
Are there any privacy or security requirements for complying with Meaningful Use in order to receive incentive money?
Yes. “Protect electronic health information created or maintained by the certified EHR through the implementation of appropriate technical capabilities”, is one of the Core Objectives Eligible Providers must meet under the Medicare and Medicaid Electronic Health Record Incentive Program. This core objective is also known as “Attestation Item #15,” which requires providers to conduct (or bring a third party to conduct) a security risk analysis, including an audit of current practice security measures in a variety of areas. Citation - 42 CFR 495.6(d)(15) (2010).
My EHR vendor is certified (or guarantees they will be certified) by one of the ONC certifying bodies like CCHIT. By using a certified EHR system, won’t I meet the Meaningful Use security objectives?
No. You will not satisfy the objective of protecting e-PHI by implementing and using a certified EHR alone: you must also conduct a security risk analysis, and as required pursuant to the HIPAA Security Rule. Compliance with the HIPAA Security Rule was mandated for most Covered Entities by April 2005.
What if I have never conducted a risk analysis, do not have a risk management program, or have not reviewed my initial risk analysis for a long period of time as required by the HIPAA Security Rule?
In July 2009, the Secretary of HHS delegated the enforcement of the HIPAA Security Rule to the Office of Civil Rights (OCR). The OCR is expected to begin random audits to ensure organizations are compliant with the HIPAA Security Rule in the near future, for the purpose of verifying that organizations have completed a risk assessment and implemented appropriate administrative, physical and technical safeguards.
Are there penalties if I am audited and found to not be compliant with the HIPAA Security Rule?
Yes. Criminal and civil penalties could be levied against organizations and/or individuals for violations of HIPAA Privacy and Security Rules. Monetary penalties for a breach of HIPAA Privacy and Security Rules range from $100 to $50,000 per violation. Additionally, state attorneys general are now authorized to bring civil actions against HIPAA violators on behalf of state residents.
What should I do to ensure I am in compliance with the Meaningful Use Core Objective # 15 (security risk analysis) as well as HIPAA Privacy and Security Rules?
Contact PaperFree Florida today to learn of more about compliance requirements for Meaningful Use Objectives, HIPAA Privacy and Security Rules and other healthcare quality improvement initiatives.
2011 E-PRESCRIBE INCENTIVE PROGRAM
INDIVIDUAL PHYSICIANS & OTHER CLINICIANS
*Please note that the terms “electronic- prescribe,” “e-prescribe,” and “eRx” are used interchangeably throughout these Frequently Asked Questions.
Do individual Eligible Professionals have to participate in “PQRS” in order to participate in the 2011 eRx Incentive Program?
- No. Individual eligible professionals (EPs) do NOT have to participate in the Physician Quality Reporting System (PQRS, formerly known as “PQRI”) in order to participate in eRx incentive program, and vice versa.
- However, practices who wish to use the Group Practice Reporting Option (GPRO) must participate in PQRS in order to be eligible, and must indicate said interest in the same self-nomination letter used to apply for the PQRS GPRO.
Does the 2011 e-Prescribe Incentive Program require use of a “certified” EHR system?
- The use of an e-Prescribe (eRx) system does not require the use of any particular system or transmission network, only that the system be a “qualified” system.
What is a “qualified EHR System?”
- A “qualified” eRx system is one that allows providers to access the following functionalities and has/uses the adopted Medicare Part D eRx standards for electronic messaging:
- Generates a complete active medication list (incorporating electronic data received from applicable pharmacies and PBMs if available)
- To generate a medication list - uses the NCPDP SCRIPT 8.1 (Corresponding PART D e-messaging standard)
- Allows EPs to select medications, print prescriptions, electronically transmit prescriptions, and conduct alerts - This functionality must be enabled
- To transmit prescriptions electronically - uses the NCPDP SCRIPT 8.1 (Corresponding PART D e-messaging std.)
- Provide information related to lower cost, therapeutically appropriate drug alternatives (if any)*
- *The ability of an electronic prescribing system to receive tiered formulary information, if available, would again suffice for this requirement for 2011.
- Uses NCPDP Formulary & Benefits 1.0 (Corresponding PART D e-messaging std.)
- Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient’s drug plan (if available).
- For Communicating Formulary & Benefits Information between Prescribers & Plans - Uses NCPDP Formulary & Benefits 1.0 (PART D)
- For Communicating Eligibility Info between the Plan & Prescribers - Accredited Standards Committee (ASC) X12N 270/271-Health Care Eligibility Benefit Inquiry and Response, Version 4010, May 2000, Washington Publishing Company, 004010X092 and Addenda to Health Care Eligibility Benefit Inquiry and Response, Version 4010A1, October 2002, Washington Publishing Company, 004010X092A1 (PART D)
- For Communicating Eligibility Info between the Plan & Dispensers - NCPDP Telecommunication Standard Specification, Version 5, Release 1 (Version 5.1), September 1999, and equivalent NCPDP Batch Standard Batch Implementation Guide, Version 1, Release 1 (Version 1.1), January 2000 (PART D)
Who is eligible to apply for the 2011 eRx Incentive Program?
- Any “Eligible Professional.” Eligible professionals are defined as: “Physicians [and other clinicians] for whom office visits, eye exams, psychotherapy or other services listed in the CMS e-Prescribing measure specifications represent at least 10 percent of their Medicare charges.”
- In other words, to be eligible for the incentive you must be an eligible professional whose estimated allowed Medicare Part B charges for the e-prescribing measure codes are at least 10% of their total Medicare Part B PFS allowed charges.
- EPs include Medicare Physicians (MDs, DOs, DMDs, Podiatrists, Optometrists, Oral Surgeons, & Chiropractors), Medicare Practitioners (PA, ARNP, CNS, CRNA, CNMW, CSW, Clinical Psychologists, Registered Dieticians, Nutritionists, & Audiologists), and Medicare Therapists (Physical, Occupational, & Speech
- The definition of EPs who can qualify for the incentive is very broad, but the payment adjustment only applies to a narrow audience.
What criteria must be met for an Eligible Professional (EP) to be considered a “successful e-prescriber” in 2011?
- The EP must electronically generate & transmit a sufficient number of prescriptions during select Medicare Part B patient encounters during the reporting period.
- In order for an Eligible Professional to be classified as a successful electronic prescriber under the 2011 eRx Incentive Program, the EP must report that he electronically generated and transmitted at least 25 unique prescriptions (25 unique eRx events) between January 1, 2011 and December 31, 2011
- In order to receive a 2011 eRx Incentive Payment, the EP must report at least 10 unique eRx encounters between January 1, 2011 and June 30, 2011.
- In order to receive a 2012 eRx Incentive Payment, the EP must report at least 25 unique eRx encounters between January 1-December 31, 2011
||Required # e-prescriptions
||Incentive will be received…
|1/1/2011 — 12/31/2011
|1/1/2012 — 12/31/2012
What is the reporting period for the 2011 E-Prescribe Incentive Program?
- The reporting period for the 2011 eRx Incentive Program is the entire calendar year, from January 1, 2011 through December 31, 2011.
- Successful e-prescribers will be eligible to receive a 2012 eRx incentive payment equal to 1% of the total estimated allowed Medicare Part B charges for all covered professional services furnished January 1- December 31, 2011.
- This amount will be based on claims submitted no later than February 28th, 2012
- Reportable event: the electronic prescribing measure is reportable by an eligible professional any time he bills for one of the designated eRx procedure codes
How do I “report” e-prescribe events? When must I submit these reports?
- Claims-Based Reporting Mechanism. This is the only approved reporting mechanism EPs can use for the purpose of avoiding the 2012 eRx payment adjustment.
- This is because CMS does not have the present ability to accept registry or EHR data within the necessary timeframe (by 1-1-2012) for complete analysis of the data & final determination of eRx status.
- However, EPs can use any qualified reporting mechanism including claims, registry, or EHR-based submissions to qualify for the eRx Incentive Payment.
- To avoid the 2012 eRx Payment Adjustment, you must submit claims no later than 7-31-2011.
- All claims for services furnished between 1-1-2011 and 6-30-2011 MUST be processed no later than 1 month after the reporting period (7-31-2011) to be included in CMS’ analysis for the 2012 eRx payment adjustment
- To avoid the 2013 eRx Payment Adjustment, you must submit claims no later than 1-31-2012.
- Other reporting mechanisms
- Registry-Based Reporting Mechanism
- “Qualified Registries” - Only registries qualified to submit EP quality measure results (and numerator & denominator data on quality measures) for the 2011 Physician Quality Reporting System (PQRS) are qualified to submit the same for the 2011 eRx Incentive Program.
- Timing of transmission - Qualified Registries will submit eRx measure for the 2011 eRx Incentive Program to CMS no later than 2-28-2012.
- List of all qualified registries for the 2011 eRx Incentive Program can be found here
- EHR-Based Reporting Mechanism
- “Qualified EHRs” – Only EHRs qualified to submit EP quality measure results (and numerator & denominator data on quality measures) for the 2011 Physician Quality Reporting System (PQRS) are qualified to submit the same for the 2011 eRx Incentive Program.
- Timing of transmission – EPs using Qualified EHRs will submit eRx measure for the 2011 eRx Incentive Program to CMS no later than 2-28-2012.
- List of all qualified EHR vendors for the 2011 eRx Incentive Program can be found here
If I report my e-prescribe data through more than one reporting mechanism, such as half through a qualified registry and half through claims-based reporting, will CMS combine the data for me to form an overall picture of my eRx activity?
- No. CMS will not combine data from multiple reporting mechanisms—an EP must make sure that the required number of eRx events for the 2011 Incentive payment is reported to CMS via a SINGLE reporting mechanism
Basics of eRx Claims-Based Reporting
- There are two essential elements - a Reporting Numerator and a Reporting Denominator
- Reporting Numerator - establishes the fact that provider has adopted a qualified eRx system and has used it for that purpose, and demonstrates at least one prescription was generated and transmitted electronically during the patient encounter
- Numerator Inclusion– eRx Code (HCPCS): G8553
- This G-code submission should be entered as the numerator on every eRx claim form and will only be considered valid if it appears on the same Medicare Part B claim containing one of the e-prescribing quality measure’s denominator codes.
- Note: Likewise, if an EP submits a Medicare Part B claim containing one of the eRx measure’s denominator codes, he can report the numerator G-code only when he actually uses a qualified eRx system to electronically generate and transmit a prescription during the patient encounter.
- Reporting Denominator - defines circumstances when the measure is reportable and consists of specific billing codes (CPT & HCPCS) for covered professional services.
- “The Denominator is any patient visit for which one or more of the following denominator codes applies…”[Applicable Codes -Denominator Inclusion]
- CPT Encounter Codes (C4): 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350;
- HCPCS Encounter Codes: G0101, G0108, G0109
- Note: patients must have at least one face-to-face office visit with the clinician during the reporting period, or that patient encounter isn’t eligible for inclusion into the EP’s eRx performance calculations (consequently phoned-in refills don’t count, but a follow-up where a refill is e-prescribed does count).
- The e-prescribe measure becomes “reportable” when any one of these specific procedure codes is billed by an EP for Part B covered professional services
- For 2011, the same 2010 eRx denominator codes have been retained
- There are no diagnosis codes in the measure’s denominator; also, reporting of eRx measure is not limited by age or gender of patient (they’re irrelevant)
- The measure is not applicable unless the EP bills for one of the codes included in the measure’s denominator
- For an in-depth overview of how to proceed with claims-based reporting, click here (CMS states that the process outlined in the linked document is still valid for 2011).
How will the Center for Medicare/Medicaid Services (CMS) determine who is a “successful e-prescriber?”
- Eligible Professional Practicing in One Location Only:
- The determination will be made at the individual professional level, based on the National Provider Identifier (NPI).
- Eligible Professional Practicing in Multiple Locations:
- In the case of individuals who are associated with more than one practice or Tax Identification Number (TIN), the determination of whether that EP is a successful e-prescriber will be made according to each unique NPI/TIN combination payment will be made to the applicable holder of the TIN
- Group Practices
- The determination will be based on whether the group practice, as a whole, has met the criteria for successful group practice e-prescribing, then payments will be made to the group as a whole
Among eligible EPs, who will actually receive 2011 eRx Incentive Program payments?
- E-Prescribe Statutory Limitation (10% Threshold)
- There is a statutory limitation on the E-Prescribing Incentive Payment—an Eligible Professional who meets the criteria for successful reporting of the e-prescribe measure [for eRx activity reported at the NPI/TIN level] still may NOT receive an incentive payment unless he meets the 10% threshold
- 10% threshold – based on whether Medicare Part B allowed charges for covered professional services to which the eRx quality measure applies are less than 10% of the total Medicare Part B PFS allowed charges for all covered professional services furnished by the eligible professional during the reporting period.
How does CMS calculate the amount of the 2011/2012 eRx Incentive Payment?
- Calculation: If the EP’s total 2011 Medicare Part B PFS allowed charges for all covered professional services submitted for the measure’s denominator codes ÷ EP’s total 2011 Medicare Part B PFS allowed charges for all covered professional services at the NPI/TIN level ≥ 10%, then the EP receives a 2011 e-Prescribe Incentive Payment
- Essentially CMS is determining whether the Medicare Part B allowed charges for covered professional services for which eRx applies are less than 10% of the total Medicare Part B PFS allowed charges for covered professional services furnished by the EP during the reporting period.
Can an Eligible Professional or Group practice receive payment under the Medicare/Medicaid EHR Incentive Program and the eRx Incentive Program?
- No double-dipping in the same calendar year!
- Statutory Limitation: ARRA, which authorized the Medicare EHR Incentive Program, specifies that the eRx incentive does not apply to an EP (or group practice), if for the EHR reporting period, the EP (or group practice) earns an incentive payment under the Meaningful Use EHR Incentive Program beginning in 2011.
- “the incentive under the eRx Incentive Program shall not apply to an EP (or group practice) if, for the EHR reporting period the EP (or group practice) receives and incentive payment under the EHR Incentive Program”
- This statutory limitation (regarding the 2011 Medicare EHR Incentive Payment) does not preclude the 10 percent limitation from applying with regard to the 2011 eRx payment adjustment to an EP who earns an EHR Incentive.
- Translation = An EP who receives payment under the Medicare EHR Incentive Program (and thus opts out of applying for the 2011 eRx Incentive payment) is still subject to the 2011 eRx payment adjustment if the EP’s office visits, eye exams, psychotherapy or other services listed in the CMS e-Prescribing measure specifications represent at least 10 percent of their total Medicare Part B PFS charges.
So, if I can’t “double-dip,” how do I maximize my incentive payments?
- An EP or group practice may decide to participate in the 2011 eRx Incentive Program (for which they may receive payments in 2012 and/or 2013), and is still eligible to participate in the Meaningful Use Medicare EHR Incentive Program starting in 2012.
- In other words, providers interested in maximizing incentive payments should pursue eRx in 2011, then register and begin reporting for MU Medicare EHR Incentive starting in 2012.
Who is generally exempt from the e-Prescribe Payment Adjustment?
- 2012 & 2013 eRx penalties will NOT apply to:
- EPs who are not licensed physicians, ARNPs, or PAs by June 30, 2011
- EPs who do not meet the 10% Medicare service threshold by June 30, 2011 (for whom office visits and services represent less than 10 percent of their allowed Medicare charges in the first six months of 2011)
- EPs who have less than 100 claims “for patient services containing visit and service codes that fall within the e-Prescribing measure specifications for dates of service between January 1, 2011 through June 30, 2011.”
Who is actually subject to 2011 and 2012 eRx Payment Adjustment, and why?
- Generally - All eligible professionals who QUALIFY for the incentive will be subject to penalties (payment adjustments) REGARDLESS of whether they actually pursue the incentive, UNLESS they qualify for a general or hardship exemption: “To avoid penalties in 2011 and 2012, eligible professionals must report e-Prescribing activity according to program details […] even if they participate in the new EHR incentive program.”
- “According to MIPPA, physicians who are eligible but choose not to participate in the 2012 or 2013 Medicare e-Prescribing incentive program and do not qualify for a significant hardship exemption would be subject to a 1 percent Medicare payment reduction based on their Medicare Part B allowed charges (1.5 percent in 2013).
- CMS is basing the 2012 penalty on e-prescribing activity that occurs during Jan. 1, 2011 through June 30, 2011. Penalties for 2013 are based on e-prescribing activity for the entire 2011 calendar year.” For examples of scenarios where EPs are subject to the penalty, see this linked FAQ from the CMS Website.
- Why? The definition of EPs who can qualify for the incentive is very broad, but the payment adjustment only applies to a narrow audience. The policy behind applying the penalty (payment adjustment) to Physicians, ARNPS, & PAs only, provided they meet the 10%/over 100 Medicare claims threshold, is meant to assure that providers who prescribe in large volumes do so electronically, and without penalizing those providers for whom the adoption and use of an eRx system is impractical due to low volume.
Who may request a hardship exemption?
- These codes are to be reported at least one time on a denominator-eligible claim during the 2012 payment adjustment reporting period
- The following parties qualify and can request the exemption through claims-based reporting, using the corresponding CPT codes:
- G8642 - EP practicing in a rural area without sufficient high-speed internet access/broadband
- G8643 - EP practicing in an area without sufficient available pharmacies for eRx
- G8644 - EP who does not have prescription privileges
What are the eRx Payment Adjustment Differentials by year?
- “To avoid penalties in 2012 and 2013, an eligible physician must report the e-Prescribing G-code, G8553, at least 25 times for Medicare office visits and other applicable services for applicable CPT codes included in the CMS e-Prescribing measure specifications on your Medicare claim forms. To avoid penalties in 2012, at least 10 of your e-prescriptions must occur and must be reported on your Medicare claim forms during the January 1, 2011 through June 30, 2011 reporting period.”
|If the EP is not a successful e-prescriber, which requires _____ prescriptions generated and transmitted electronically,
||For the eRx reporting period, _____...
||Then the PFS amount for covered professional services furnished by those EPs during that year shall be less than the PFS amount that would otherwise apply over the next several years by…|
||January 1- June 30, 2011
||January 1- December 31, 2011
*Pending release of 2012 Medicare PFS Final Rule, which should contain updates about
the 2013 eRx incentive Program and information about the 2014 Payment Adjustment.
How do I assess my own e-prescribing progress for 2011? Will CMS provide this information for me?
- CMS will not make available or tell eligible professionals (or group practices) the percentage of the prior year’s Medicare charges resulting from the outpatient CPT codes included in the eRx measure specifications.
- If EPs want info about the composition of Medicare charges they should consult their electronic billing system. They may also use feedback reports to help in this regard.
I heard CMS will provide Feedback Reports telling providers whether they have met the requirements to become successful e-prescribers—what is it? When can I expect mine?
- Annually - CMS will provide EPs with annual feedback reports on whether EPs have successfully completed all requirements of the eRx program.
- Interim Feedback Reports: CMS will make available to any RP who bills for a denominator-eligible case from January-June 30, 2011. The interim feedback reports will be available in the fall of 2011 and will include information related to the 2012 eRx payment adjustment.
- Questions arising out of I.F.R.s, or regarding eligibility for the eRx incentive, should be addressed to the “Quality Net Help Desk” via e-mail at firstname.lastname@example.org
I do e-prescribe, but some of the area pharmacies that my patients prefer do not currently accept prescriptions electronically—does it count if I e-prescribe to those pharmacies too?
- Yes. The use of a pharmacy that cannot receive an electronic prescription DOES NOT invalidate the eRx event and the EP will still get credit for electronic prescribing, so long as he reports this event for a denominator-eligible visit.
- Example: Some physicians have patients that participate in the Medicaid PACE program and use contracted pharmacies, which may not be able to receive electronic prescriptions. Visits from patients like these are not excluded from the eRx incentive program, so long as the EP uses a “qualified” EHR to send the prescription electronically and reports it as such, even if the pharmacy is only equipped to receive faxes or calls.
Does it count towards my e-prescribe total if I send a fax or phone in a script to a pharmacy that is not equipped to receive prescriptions electronically?
- No. The use of a pharmacy that cannot receive an electronic prescription doesn’t invalidate the eRx event if the provider actually generates and transmits the prescriptions electronically. Generating and transmitting prescriptions via phone or fax to a pharmacy is not sufficient for the purposes of the eRx Incentive Program.
Public Reporting of Successful E-Prescribers
- CMS will post the names of eligible professionals and group practices that are successful e-prescribers for the purposes of the 2011 eRX Incentive Program on the Physician Compare website.
- CMS will publish individual names/group practice names without regard to whether the 10% threshold limitation applies to that individual or practice, and without regard to whether the individual or practice actually earns or receives an incentive payment.
For more information on the 2011 e-Prescribe Incentive Program or the associated penalties, please visit the CMS website.
Group Practice Defined
- An organization with a single Tax Identification Number (TIN) comprised of two or more eligible professionals, as identified by their individual National Provider Identifier (NPI), who have reassigned their Medicare billing rights to the TIN.
- The definition includes group practices participating in approved Medicare demonstration projects—these group practices are for all intents and purposes viewed as participating in PQRS even though their actual project is a functional PQRS equivalent
- The eRx group practice reporting option (GPRO) is consistent with the definition of “group practice” under the Physician Quality Reporting System (PQRS) group practice reporting option (GPRO)
Limitations on the Group Practice Reporting Option
- The eRx GPRO is limited to group practices already participating in the PQRS GPRO, or to group practices participating in approved Medicare demonstration projects, that have indicated their desire to participate in eRx via a self-nomination letter in which the reporting mechanism is also specified.
- Unlike individual EPs, who may choose not to participate in PQRS, in order to be eligible for the eRx incentive the group practices wishing to participate in the eRx GPRO MUST already participate in PQRS (or a functional equivalent)
- Timing of opt-in: a group practice must indicate their desire to participate in the eRx Incentive Program at the same time they indicate a desire to participate in PQRS (via the same self-nomination letter)
- See the PQRS page of CMS website for details
Group Practice Reporting Mechanisms
- All three mechanisms—claims, qualified registry, and qualified EHR—are permissible for data submission on eRx measure for the purposes of qualifying for the 2011 eRx incentive payment;
- As in the case of individual EPs, the group practice must meet the relevant 2011 GPRO reporting criteria for the 2011 incentive using a SINGLE reporting mechanism—CMS will not combine data from multiple reporting mechanisms
Group Practice Reporting Period
- For the 2011 eRx incentive payment, the reporting period is January 1- December 31, 2011.
Group Practice Reporting Options
- GPRO I - This is the reporting option for large group practices with 200 or more EPs
- In order for a GPRO I practice to be classified as a successful electronic prescriber in 2011, the GPRO I practice must report that it electronically generated and transmitted at least 2,500 unique prescriptions (2,500 unique eRx events) between January 1, 2011 and December 31, 2011
- GPRO II - This is the reporting option for smaller group practices with less than 200 EPs
- The reporting criteria for GPRO II practices differs according to practice size; in order to be classified as a successful electronic prescriber in 2011, the GPRO II practice with _______ EPs must report that it electronically generated and transmitted at least ______ unique prescriptions (unique eRx events) between January 1, 2011 and December 31, 2011
eRx Group Practice Reporting Option
Group Size (# of Eligible Professionals)
Required # of Unique Visits (where an eRx was Generated) to be a Successful e-Prescriber
||200 & up
What if a Group Practice applies for the for the 2011 eRx Incentive, but individual members have already applied for/received Medicare EHR Incentives?
- No double-dipping -- CMS will assess the group practice data first to determine eRX incentive eligibility. If the group practice is eligible, then CMS will filter out the allowed charges for all NPIs who earn the EHR incentive before calculating the group’s incentive amount.
Group Practice Hardship Exemptions
- The same information (codes and qualifications) outlined for eligible professionals applies to Group Practices
Why are the thresholds for e-prescribing different for the 2011 eRx Incentive Program and the Medicare/Medicaid EHR Incentive Program?
- 2011 Medicare EHR Incentive = 40% of all permissible prescriptions must be generated and transmitted electronically during the reporting period
- 2011 eRx Incentive = 25 unique prescription events during the reporting period
- CMS finds the different thresholds appropriate because EHR Incentive Program is voluntary, while compliance the eRx Incentive Program is mandatory to maintain full payment for Medicare Part B services.
Public Reporting of Successful E-Prescribers
- CMS will post the names of eligible professionals and group practices that are successful e-prescribers for the purposes of the 2011 eRX Incentive Program on the Physician Compare website.
- CMS will publish individual names/group practice names without regard to whether the 10% threshold limitation applies to that individual or practice, and without regard to whether that individual or practice actually earns and/or receives an incentive payment.
For more information on the 2011 e-Prescribe Incentive Program or the associated penalties, please visit the CMS website
Other FAQscoming soon