E-Prescribing - Eligibility, Reporting, Incentives, Penalties, and Systems

The Medicare Improvements for Patients and1. 1.0% for 2012
Providers Act of 2008 (MIPPA) authorized2. 1.5% for 2013
incentives for physicians to utilize electronic3. 2.0% for 2014 and each subsequent year
prescribing (e-prescribing). The incentives tookQualified e-Prescribing systems:
effect January 1st 2009. As is typical for- In order to qualify for the Medicare e-prescribing
Medicare, a carrot and stick approach has beenincentive, practitioners must use a
implemented to encourage physicians to take partâqualifiedâ system
in the program. The following is summary of the- Qualifying systems must support a strict list of
salient points and some issues to considerfunctionalities and interoperability standards
regarding e-prescribing:designated by CMS
Eligibility requirements:- All EMR systems that obtain the Certification
- Physician or other recognized health careCommission for Health Information Technology
practitioners (including Physicians assistants and(CCHIT) 2008 certification will qualify. In 2009,
Nurse Practitioners)CCHIT will begin certification for stand-alone
- At least 10% of annual Medicare charges pere-prescribing systems
practitioner must come from a list of approved- Practitioners should obtain written guarantees
Medicare CPT codes. The designated code list isfrom e-prescribing or EMR vendors that the
primarily comprised of common office visit, orsystems meet all CMS e-prescribing requirements
outpatient consult CPT codes (e.g. 99203, 99213,Types of e-Prescribing Systems
99243, 99244). Most office based primary care- EMR system vs. stand-alone
physicians and specialists should easily qualify for
the 10% requirement1. Stand-alone systems make more sense for
- Must use a qualified e-prescribing system (seepractices not planning on implementing EMR in the
below)foreseeable future
- Pertains only to patients enrolled in traditional2. Stand-alone e-prescribing systems are generally
Medicare. The e-prescribing initiative does notless costly and simpler than EMR systems
apply to patients in Medicare Advantage programs3. EMR systems' e-prescribing applications may
How to report e-Prescribing to Medicare:offer better functionality
- Three new G-codes have been developed by4. Unlike EMR, stand-alone systems many times
Medicare to designate e-prescribing;are separate from practice management systems
and thus may require double entry of data
1. G8443 to report that all prescriptions in- Locally installed vs. web applications
connection with the visit billed were electronically
prescribed1. Locally installed applications are installed and run
2. G8445 to report that no prescriptions weredirectly on practiceâs computers. Data is
generated during the visitstored on computer(s) in the office
3. G8446 to report that some or all prescriptions2. Web services are accessed through the
were written or phoned in due to patient request,Internet. Data is stored on the web server
State or Federal law, the pharmacy's system3. Locally installed e-prescribing applications may
being unable to receive the data electronically orhave higher up-front costs and require
because the prescription was for a narcotic ormaintenance such as data back-ups. Internet
other controlled substanceconnections are not needed to access the
- Practitioners must include one of the aboveapplications but are necessary to transmit
three G codes when they bill Medicare along withprescriptions
approved CPT codes to qualify the visit as an4. Web services generally require the Internet to
e-prescribing eventaccess the applications and may be slower than
- At least 50% of Medicare applicable claims perlocally installed programs. Some practices may
year must be billed with a G code in order tohave concerns regarding storing clinical data on
qualify for the Medicare incentivee-Prescribingoutside system
incentives payments:- Hand-held or PC-based systems
- Payments are based upon the total allowed Part
B charges billed by providers per annual reporting1. Hand-held PDAs allow convenient access to
periode-prescribing applications and obviate the need and
- Providers are paid a percentage of thosecost of computers in every location
charges based on the following schedule:2. Hand-held applications generally do not have the
same functionality and ease of use as PC-based
1. 2.0% for 2009e-prescribing systems
2. 2.0% for 20103. Some e-prescribing applications allow for both
3. 1.0% for 2011hand-held and PC-based systems prescription
4. 1.0% for 2012writing
5. 0.5% for 2013e-Prescribing penalties:In 2009 there appears to be a significant increase
- Beginning in 2012, providers not reportingin government support for medical practices to
successful e-prescribing to Medicare will be"go electronic" whether it be e-prescribing or EMR
penalizedEHR. Practices should consider implementing EMR
- Penalties will also be based upon total allowedand e-prescribing systems in the near to mid
Part B charges billed by providers per annualterm to take advantage of subsidies and incentive
reporting periodpayments. In the longer term, it is likely that
- Provider's Medicare payments will be reducedsupport for electronic will turn into mandates from
according to the following schedule:both government and private payers.