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:

*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.

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.

Let’s take a look at how much the EMR stimulus Medicare penalties will amount to for those doctors who choose not to show “meaningful use” of a “certified EHR.”

At AAFP I learned that the average physician practice has revenues of about $500,000. Certainly there are many with more and some with less, but you can substitute your number into the calculation. I also learned that the average AAFP user does about 20% Medicare. Of course, each practice can pull up their own figures.

Using these averages, that means that the average practice does about $100,000 in Medicare reimbursement.

The penalties for now showing meaningful use of a certified EHR are:
2015 – 1%
2016 – 2%
2017 – 3%
2018 – 4% (HHS Secretary Option)
2019 – 5% (HHS Secretary Option)
or…using the Medicare numbers above that calculates out to:
2015 – $1000
2016 – $2000
2017 – $3000
2018 – $4000
2019 – $5000

Of course, this doesn’t take into account that many think the penalties will be delayed and may never go into effect. However, is $1000-$5000 of penalties worth the effort to show meaningful use? Although, when you add the Medicare penalties above, no matter the amount, on top of the other Medicare cuts and you can understand the outrage when it comes to Medicare.

This is certainly only one part of the EHR decision making process. However, it does illustrate well why the EMR stimulus penalties aren’t motivating providers to implement EHR software.