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Meaningful Use Measures: ePrescribing – Meaningful Use Monday

Posted on April 18, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

I hope that by now, readers have heeded the advice I gave in a previous post, “No Matter What Else You Do in 2011, You’ve Got to ePrescribe” and are covering their bases regarding ePrescribing under MIPPA. Even though providers can’t collect a meaningful use incentive (as a Medicare participant) during the same year that they earn an ePrescribing incentive, having the ePrescribing workflow in place for MIPPA purposes will prepare them well for meaningful use.

Meaningful Use Core Measure: ePrescribing

More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

This is a core, i.e., required, measure that can only be excluded by an EP who writes fewer than 100 prescriptions during the reporting period and attests to that number of prescriptions. A continuing ePrescribing challenge faced by some specialists is the inability to ePrescribe Schedule II-V drugs. CMS took that issue off the table—at least for the purposes of meaningful use—by limiting the calculation to “permissible prescriptions.” (The definition of “permissible” excludes controlled substances because it is based on the rules that were in place in January 2010, when the Final Rule on Meaningful Use was published.)

The good news about the ePrescribing measure is that in the course of satisfying this one measure, providers will be simultaneously addressing 4-5 other measures—CPOE, maintaining a medication list, drug-to-drug and drug-allergy checks, and the menu measure requiring implementation of a drug formulary. Of this list, those that require more than simply “enabling the functionality” will be the topics of future Meaningful Use Monday posts.

Important notes about MIPPA and EHR Incentives:

  • It is possible to be deemed a successful ePrescriber in one program, but not the other, because the two programs have different specifications, so make sure to understand the rules for each.
  • If you choose to pursue the EHR incentives rather than the ePrescribing incentives this year, you must still continue to comply with the MIPPA requirements, (i.e., use the G-Code), to avoid 2012 and 2013 penalties.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Meaningful Use Monday – Follow-up on ePrescribing

Posted on February 28, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

The last Meaningful Use Monday post detoured from the EHR incentives to ePrescribing under MIPPA—given its importance based on the impending schedule of penalties. Because I receive ePrescribing questions on a daily basis, I thought a quick recap of ePrescribing basics might be helpful:

  • Incentives and penalties:
Year Incentives* Penalties*
2011 1%
2012 1% 1%**
2013 0.5% 1.5%**
2014 on 2%

*Percent of provider’s total Medicare Part B FFS Allowable Charges. (Incentives assume provider does not receive EHR incentive for that year.)

**Based on 2011 ePrescribing activity

  • Incentives are earned per provider, and each provider must individually meet the requirements. This means that some providers within a practice might qualify for an incentive, while others might incur a penalty. (Group reporting options exist, but they are limited and require qualification.)
  • Reporting is by G-Code and there is only one: Use G-8553 on the Medicare claim to report that “at least one Rx was generated and transmitted using a qualified ePrescribing system during the patient encounter.”
  • Surescripts certification qualifies an ePrescribing system. (This is distinct from the ONC-certification required for meaningful use.)
  • Provider eligibility:
    • MD, NP, or PA with prescribing authority
    • At least 100 encounters with the specified CPT codes
    • Specified CPT codes must constitute at least 10% of the provider’s Medicare charges.
  • To request exemption from penalties, use the following G-Codes on one Medicare claim before June 30, 2011:
    • Hardship Code G-8642: Rural area with limited high-speed internet access
    • Hardship Code G-8643: Limited pharmacies for ePrescribing
    • G-8664: Although an eligible provider, you do not have prescribing privileges

In a future post, Meaningful Use Monday will look at ePrescribing in the context of meaningful use.

Lynn Scheps is Vice President, Government Affairs at EMR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Meaningful Use Mondays – ePrescribing Penalties and MIPPA

Posted on February 14, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

No Matter What Else You Do in 2011, You’ve Got to ePrescribe

With all of the focus on meeting meaningful use, the requirements related to ePrescribing under the Medicare MIPPA program seem to be getting lost in the shuffle. Just as some practices didn’t get the message about the 2010 change in ePrescribing G-codes until late in the year, I am hearing that the communication hasn’t reached everyone about the importance of ePrescribing in 2011; so I thought I would post a reminder:

2011 ePrescribing activity will be the basis for the 2012 and 2013 ePrescribing Medicare penalties (AKA “adjustments”) under MIPPA. If you are not already ePrescribing, it’s important to start very soon. The following are the rules:

  • ePrescribe on 10 Medicare encounters between now and June 30, 2011 to avoid a 1% reduction in 2012 Medicare rates.
  • ePrescribe on 25 Medicare encounters between now and December 31, 2011 to avoid a 1.5% adjustment in 2013.
  • By ePrescribing 25 times, you can also earn the 1% ePrescribing incentive in 2011.

Note, however, that the legislation does not allow providers to collect both the ePrescribing and EHR incentives (as a Medicare provider) in the same year, so you must make a choice: Collect the MIPPA incentive in 2011 and start pursuing meaningful use in 2012—a strategy discussed by Evan Steele in EMR Straight Talk—or forego the MIPPA incentive in 2011 and attest to meaningful use in 2011. In either case, you must continue to comply with MIPPA requirements to avoid the future penalties associated with that program.

Lynn Scheps is Vice President, Government Affairs at EMR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.