What is the Medicare e-Prescribing (eRx) Incentive Program?
Section 132 of Medicare Improvements for Patients and Providers Act (MIPPA) of 2008 authorizes a new incentive program for eligible professionals who are successful electronic prescribers (E-Prescribers) as defined by the Act. The program, which will begin in January 2009, will allow physicians to receive incentive payments equal to: 2% of total Medicare Part B payments in 2009 and 2010, 1% in 2011 and 2012, and 0.5% in 2013. After 2013, the bonus program will be phased out. Eligible professionals who do not adopt e-Prescribing will face the following penalties: 1% reduction in covered Medicare Part B payments in 2012, 1.5% in 2013, and 2% in 2014 and beyond. The e-Prescribing measure 125 from the 2008 PQRI program will be used for the 2009 e-Prescribing bonus program. The measure will be removed from the 2009 PQRI program.
What must I do to become a successful electronic prescriber?
Physicians are eligible for the incentive program if at least 10% of total Medicare Part B payments come from a list of 33 office-based service codes. Also, in order to qualify physicians must successfully report that they e-prescribed or attempted to e-prescribe at least 50% of the time during these eligible situations. The incentive payment would be applied to all payments under Medicare Part B and not just for e-prescribing claims or office visits.
Therefore, physicians would report one of three G codes below as a numerator on claims with one of the 33 codes below as a denominator. The numerator codes are:
- G8443 – to report using an e-prescribing system for all prescriptions.
- G8445 – to report using a qualified e-prescribing system, but that you didn’t generate any prescriptions during the encounter.
- G8446 – to report using a qualified e-prescribing system, but:
- You didn’t e-prescribe due to state or federal law or regulations that required you to phone in or print the prescription.
- You didn’t e-prescribe one or more prescriptions because they were for narcotics or other controlled substances.
- The patient requested that you phone in or print the prescription.
- The pharmacy system cannot receive electronic transmissions.
Services or patient encounters to be used as the denominators for e-prescribing include E/M visits and consultations. The CPT or HCPCS codes for the denominator are: 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, G0101, G0108 and G0109.
Summary for successful electronic prescribing:
| If you use any one of the following codes: |
Report one of the following codes: |
| 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, G0101, G0108, G0109 |
- G8443 (prescription by e-prescribing)
- G8446 (some prescriptions handwritten)
- G8445 (no prescriptions written)*
* Note: Always use one of the codes above when e-prescribing.
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What are some of the challenges physicians may face with this new program?
- It is a voluntary program and so a physician may e-prescribe but the pharmacies are not obligated to accept the e-prescription.
- No registration is required for the program and you can begin reporting for the bonus at anytime in 2009, however, physicians would need to successfully report any of three e- prescribing G codes 50% of the time during the calendar year. So physicians could conceivably wait until April 1, but they would then have to report 75% of the time or if physicians waited until July then they would report 100% of the time.
- The estimated cost of adopting e-Prescribing is $3,000 per doctor.
- The DEA requires an intricate system of checks and cross-checks under e-Prescribing, both human and programmed, which could require one workflow for controlled substances and another for non-controlled substances.
- Practices with an existing EHR may find that their vendor products do not have a qualifying e-Prescribing module. Qualifying standalone systems are available and can be researched on the SureScripts website. The Certification Commission for Healthcare Information Technology (CCHIT) plans to certify standalone e-Prescribing systems in 2009.
What are the pros and cons of a standalone versus an integrated e-Prescribing system?
| Standalone e-Prescribing System |
Integrated e-Prescribing System |
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Pros:
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Pros:
- One integrated system provides flexibility and convenience with minimal workflow errors and disruptions.
- Allows for electronic access to all patient data stored in the EHR, including diagnoses, problem lists, clinical notes, laboratory and radiology results and orders.
- Increased efficiency due to integration with practice management software for demographic info, billing and scheduling.
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Cons:
- Redundant data entry of demographic information.
- Should the decision be made to purchase an EHR, there is the potential trouble of transferring e-prescribing data from a stand-alone into the new EHR.
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Cons:
- Significantly more expensive then the stand-alone option.
- Return on investment a concern for small practices, rural settings, and inner city locations.
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