Medicare and Electronic Prescribing
eRx
FOR THOSE PROVIDERS UTILIZING JUNE 30, 2011 FOR YOUR DEADLINE TO MEET YOUR 10 OR 25 PRESCRIPTION REQUIREMENT - PLEASE READ THIS IMPORTANT MESSAGE....
This information was released today following a meeting held yesterday at the CMS Regional Offices in Kansas City.
This is to clarify significant points related to the electronic prescribing (eRx) incentive program and the related adjustments.
To avoid being subject to the 2012 eRx payment adjustment of 1% of the otherwise applicable physician fee schedule amount, physicians must have submitted at least 10 eRx G-codes (G8553 - at least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system) on eligible claims with dates of service between January 1, 2011 and June 30, 2011.
For the 2012 eRx payment adjustment analysis, CMS is allowing JUST ONE MONTH to receive submitted claims into the National Claims History (NCH) file. Since claims are only submitted to the NCH every Friday, the last Friday would be July 29, 2011. Eligible professionals are encouraged to submit these special claims to WPS by mid July, 2011, or earlier to ensure they will arrive into the NCH on time!
Simply put - you normally have 365 to file a Medicare claim. However - for claims utilizing the G8553 code (in order to meet the eRx requirement of at least 10 claims) - those claims must be received by WPS prior to July 29, 2011. You are encouraged to submit them by the middle of July to ensure that they will be "counted" towards your requirement in order to avoid the 1% payment adjustment in 2012. Please keep in mind that just because you send your claims on a particular day, your clearing house may take several days to do their processing before they send those claims to WPS.
Another clarification is that if you have already submitted a claim and neglected (for any reason) to include the G8553 code, you CAN NOT resubmit or re-open a claim to add this information.
Some other new developments:
Significant Hardship Exemption:
Under current rules, there are two significant hardship exemption categories under which a physician can be exempted from this 2012 payment adjustment:
- practices in a rural area without sufficient high-speed internet access and reports the code G8642 at least once on a claim between January 1, 2011 and June 30, 2011 or
- practices in an area without sufficient available pharmacies for electronic prescribing and reports code G8643 at least once on a claim between January 1, 2011 and June 30, 2011
In summary, under current law, unless a physician meets one of the existing hardship exemptions, he or she will be subject to reduced physician fee schedule payments in 2012 if the required eRx information described above is not reported.
Notice of Proposed Rulemaking (NPRM):
On May 26, 2011, CMS issued an NPRM that would, among other things, expand the circumstances under which compliance with the eRx payment adjustment requirements would constitute a significant hardship. These include:
- Limited prescribing activity
- Inability to electronically prescribe due to local, state or federal law
- Insufficient opportunities to report eRx measures due to limitations of the measure’s denominator
- Eligible professionals who register to participate in the Medicare EHR Incentive Program or Medicaid EHR Incentive Program and adopt certified EHR technology
If finalized as proposed, the NPRM would also extend the deadline to request a significant hardship exemption for the two original categories, as well as the proposed additional categories, to October 1, 2011. In addition to submission of such request by letter, the NPRM envisions possible submission of such requests via a web-based tool.
The NPRM can be found at the following location: http://www.gpo.gov/fdsys/pkg/FR-2011-06-01/pdf/2011-13463.pdf <http://www.gpo.gov/fdsys/pkg/FR-2011-06-01/pdf/2011-13463.pdf>
The NPRM comment period ends July 25, 2011. We encourage you and your members to submit your comments and concerns.
Aside from commenting on the NPRM, there is no action a physician needs to take at this time related to the proposed expansion of hardship exemptions. If the physician qualifies under one of the existing hardship exemption categories, the claim-related reporting of G8642 or G8643, as appropriate, constitutes that request.
Following is a link to the tip sheet that was mentioned that addresses the PQRS, ERx and EHR Incentive programs. http://www.cms.gov/MLNProducts/downloads/EHRIncentivePayments-ICN903691.pdf
Also, the QualityNet Help Desk is available to answer questions related to the PQRS and eRx incentives. That number is: 866-288-8912.
