This year, CMS has launched the e- Prescribing Incentive Program to encourage physicians to adopt e-Prescribing (for information on the future of e-prescribing incentives, see this month's "Technology Connection," p. 59). In 2008, as part of the Physician Quality Reporting Initiative (PQRI), physicians were rewarded for using electronic prescribing for a limited set of codes. Now, additional codes have been added to those that qualify. Those likely to be used by dermatologists are the office based E/M codes: 99201–99245. Providers likely to be working in dermatology who qualify are physicians, nurse practitioners, and physician assistants.
The incentive program applies only to the original Medicare Program, not to Medicare Advantage Plans. Incentive payments are: two percent for 2009 and 2010, one percent for 2011 and 2012, and 0.5 percent for 2013. On the other side of that coin, starting in 2012, eligible providers who are not e-prescribing will be subject to a penalty. In 2012, providers who are not e-prescribers will be subject to a one percent reduction in all Medicare payments, 1.5 percent in 2013, and two percent in 2014 and beyond.
Although this seems to amount to another unfounded mandate, there are exceptions to the Stark and Anti- kickback rules that may allow for donation of systems. The American Medical Association has additional information about donations. Go to www.ama-assn.org.
There are advantages to e-prescribing other than the financial incentives.
- Formulary and benefit transactions provide prescribers with information about which drugs are covered by a Medicare patient's prescription drug benefit plan, eliminating calls from the pharmacy asking for a substitution.
- Medication history transactions provide information about medications a patient is already taking, including those prescribed by other providers, to help reduce adverse drug events.
- Fill status notifications allow prescribers to receive electronic notification from the pharmacy letting them know whether the patient has picked up the prescription or if it was partially filled.
- Refill requests can be handled electronically.
Requirements for a qualified system are that it must:
- Generate a complete medication list that incorporates data from pharmacies and benefit managers (if available).
- Select medications, transmit prescriptions electronically* using the applicable standards, and warn the prescriber of possible undesirable or unsafe situations.
- Provide information on lower cost therapeutically appropriate alternatives (for 2009, tiered formulary information, if available, meets this requirement).
- Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient's drug plan.
*The prescription must be sent electronically. If the network converts the electronic prescription to a fax because the pharmacy can't receive electronic faxes, this counts as e-prescribing. If the e-prescribing system is only capable of sending a fax directly from the e-prescribing system to the pharmacy, the system isn't a qualified e-prescribing system.
The codes used for reporting in the incentive program are:
- G8443. Used a qualified e-prescribing system for all of the prescriptions.
- G8445. Had a qualified e-prescribing system, but didn't generate any prescriptions during this encounter.
- G8446. Had a qualified e-prescribing system but prescribed narcotics or other controlled substances. (The DEA currently prohibits e-prescribing for controlled substances)
- G8446. Had a qualified e-prescribing system and state or federal law required that the prescription be called in or printed.
- G8446. Had a qualified e-prescribing system and the patient asked that the prescription be phoned in or printed.
- G8446. Had a qualified e-prescribing system and the pharmacy system cannot receive electronic transmissions.
The measures are reported only on codes for which they are eligible; in the case of dermatology services that would be E/M services.
To qualify for the incentive, the measures must be reported on at least 50 percent of the claims that are eligible. To be eligible for the incentive, the estimated allowed Medicare Part B charges for the e-prescribing measure must be at least 10 percent of the total Part B allowed charges for that provider.
We contacted CMS to ask the obvious question: If a provider does not report during the incentive period because he/she does not expect the eligible codes to total at least 10 percent of Medicare revenue, will that provider be penalized when the penalties begin? We were told that since the penalty phase is still some time off, rules regarding that issue will probably be made in the future.
If you have a system that meets the requirements, use it and report it. Also, if you are considering purchasing a prescription writing system or an EMR system with prescription writing capability, make certain the system you buy meets the CMS requirements.
This article is by no means intended to be complete information on e-prescribing. Additional information is available at the sites below.
For more information on e-prescribing: