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New Opportunities to Avoid ePrescribing Penalty for 2013 – Meaningful Use Monday

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According to the 2013 Medicare Final Rule released last week, there are new ways to avoid future payment adjustments under the MIPPA ePrescribing rule for those who have not already taken the necessary steps to avoid them: 1) The exemption request period has been reopened and 2) meaningful use will satisfy the ePrescribing requirements according to specific timetables.

1) CMS is offering a second chance to physicians who missed the June 30 deadline for requesting an exemption to the 2013 ePrescribing penalty (1.5%) under the original 4 categories. Between November 1, 2012 and January 31, 2013, physicians can go to the Quality Reporting Communication Support Page and request an exemption based on one of the following justifications:

  • Inability to electronically prescribe due to local, State, or Federal law or regulation (i.e., prescribe predominantly controlled substances)
  • Prescribed fewer than 100 prescriptions between January 1 and June 30, 2012
  • Insufficient high speed internet access (i.e., rural area)
  • Insufficient available pharmacies that accept electronic prescribing.

2) In the interest of harmonizing the various government programs that contain ePrescribing components, CMS now will provide two additional ways to avoid the 2013 MIPPA penalties:

  • Achieve meaningful use during 2013
  • Demonstrate intent to participate in the EHR Incentive Program and adopt Certified EHR Technology by January 31, 2013

This information will be retrieved by CMS from the information in its EHR Incentive Program’s Registration and Attestation System, rather than by having providers request an exemption as in #1 above.

November 5, 2012 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.

ePrescribing in 2012: Keep On G-Coding – Meaningful Use Monday

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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.

Many physicians will be pursuing EHR incentives in 2012. Because meaningful use is not dependent upon G-codes, providers have been asking whether they need to continue putting “G-8553” on Medicare claims. The answer is YES—keep on G-Coding! 

Even though physicians who receive a Medicare EHR incentive are ineligible for an ePrescribing (MIPPA) incentive, they are still subject to future ePrescribing penalties. These penalties can be avoided by ePrescribing in 2012:

  • Prevent the 2013 (1.5%) penalty – CMS is giving providers a second chance. If you failed to ePrescribe on the minimum 25 Medicare encounters in 2011, (which would have already protected you from the 2013 penalty), report G-8553 10 times between January 1 and June 30, 2012 on any Medicare claims. These claims don’t even have to be for the specified CPT “denominator” codes.
  • Prevent the 2014 (2%) penalty – Report the G-code 25 times between January 1 and December 31, 2012. These claims must be associated with the specified CPT codes (typically E&M visits). 

If you are not pursuing meaningful use in 2012—or if you are, but for some reason fail to earn the incentive this year—you can still earn a 1% ePrescribing bonus under MIPPA if you report the G-Code on claims with the specified CPT codes 25 times between January and December . 

Like last year, there will be a process for requesting an exemption from the 2013 penalties, but surprisingly, the Proposed Rule did not include earning an EHR incentive as one of the justifications.

January 23, 2012 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.

Meaningful Use Measures: ePrescribing – Meaningful Use Monday

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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.

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.

Meaningful Use Monday: How Will You Actually Get Your Meaningful Use Money?

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There is a great deal of skepticism about when EHR incentives will be paid and how providers will actually get their money. This is not surprising, given the negative early experiences with the PQRI program and the fact that ePrescribing providers are having to wait until September or October to receive their bonuses for the prior year for the MIPPA incentive program.

The good news is that CMS is promising to distribute the first EHR incentives in May, following successful attestations of meaningful use for the initial 90-day reporting period.

So how will this happen? A common misconception is that the first year incentives are automatically $18,000. According to the legislation, the incentives are earned at a rate of 75% of Medicare Part B FFS Allowable Charges up to the maximum, (i.e., $18,000 for year 1). What this means is that once a provider successfully attests to meeting meaningful use, CMS will check to see if he/she has generated sufficient Medicare revenue to warrant the $18,000 incentive—i.e., $24,000 in charges. If so, CMS will issue the check. If not, CMS will wait until the provider reaches $24,000 and then release the incentive payment. For the few providers with very small Medicare populations, CMS will wait until February 2012 to receive all of the provider’s claims for 2011, and then send an incentive in the amount of 75% of his/her 2011 Medicare charges.

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.

March 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.

Meaningful Use Monday – Follow-up on ePrescribing

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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.

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.

Meaningful Use Mondays – ePrescribing Penalties and MIPPA

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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.

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.

Meaningful Use Mondays – Participation Under Medicare vs. Medicaid

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Physicians who are eligible for both programs will likely find participation under Medicaid to be a preferable option because the incentives are higher, the first year rewards adoption/purchase, (without requiring demonstration of meaningful use depending on the state); and the program offers more flexibility in terms of time frames. To participate under Medicaid, a provider must have a practice that is 30% Medicaid (20% for pediatricians), based on number of patient encounters (as opposed to revenue). Some providers are only eligible under Medicaid—nurse practitioners; certified nurse-midwives; dentists; and physician assistants who practice in a Federally Qualified Health Center or rural health clinic that is led by a physician assistant.

Not all states have their EHR incentive programs ready to go yet. 14 states will launch in either January or February; others are expected later in the year.

The major differences between the Medicare and Medicaid incentive programs that providers should take into consideration when making their choice at registration include the following:

MEDICARE MEDICAID
Maximum Incentive $44,000 over 5 years

(+10% for EPS in HPSAs)

$63,750 over 6 years ($42,500 for pediatricians w. 20-30% Medicaid)
First payment year Requires meaningful use $21,250 for adoption, imple-

mentation, upgrading to EHR

($14,167 for pediatricians w. 20-30% Medicaid)

Latest start time to earn maximum 2012

Must start by 2014 to qualify for any incentives

2016
Last payment year 2016 2021
Eligibility for concurrent ePrescribing bonus (MIPPA) No Yes

Next Monday’s post will highlight some other differences between the two programs that are interesting, but less influential.

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.

January 10, 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.