CMS Finalizes Incentive Program
The Centers for Medicare & Medicaid Services (CMS) has finalized provisions affecting the 2010 E-prescribing Incentive Program. As in 2009, eligible professionals who adopt a qualified e-prescribing system and successfully report the e-prescribing measure will earn a bonus of 2 percent of the total estimated Medicare Part B Physician Fee Schedule (PFS)-allowed charges for all covered professional services furnished during the 2010 reporting period.
The same criteria from 2009 are used to establish whether an e-prescribing system qualifies. The system must be able to do the following tasks:
- Generate a complete active medication list incorporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs), if available
- Select medications, print prescriptions, electronically transmit prescriptions, and conduct all alerts
- Provide information related to lower cost, therapeutically appropriate alternatives, if any (The availability of an e-prescribing system to receive tiered formulary information, if available, would meet this requirement for 2010.)
- Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient’s drug plan, if available
- Meet Medicare Part D standards (Practices should consult with their vendor to determine whether their system meets these standards.)
Changes for 2010
Quality data may be reported on the 2010 e-prescribing measure through claims, a qualified registry, or a qualified Electronic Health Record (EHR) system. Only registries and EHRs that qualify for the 2010 Physician Quality Reporting Initiative (PQRI) and have the capability to report the e-prescribing measure can submit data on the e-prescribing measure for 2010. Additional information on registry-based or EHR-based reporting mechanisms for the program is available on the CMS Web site at www.cms.hhs.gov/erxincentive
To be considered a successful e-prescriber and qualify to earn the incentive payment, an individual eligible professional must report the e-prescribing measure for at least 25 patient encounters during 2010. The e-prescribing measure is reportable when one of the service or procedure codes listed in Table 1 is billed for covered professional services under Medicare Part B.
Reporting in 2010 has been simplified so that eligible professionals will only need to report one G-code (G8553). This code indicates that at least one prescription created during the patient encounter was generated and transmitted electronically using a qualified e-prescribing system.
A group option
Beginning in 2010, a group practice may also qualify to earn an incentive payment equal to 2 percent of the practice’s total estimated Medicare Part B PFS-allowed charges. The group practice must meet the reporting criteria specified by CMS. This option enables groups of 200 or more eligible professionals operating under one tax identification number to submit 2,500 separate e-prescribing events to qualify for the bonus.
Group practices may choose to report the e-prescribing measure through claims, a qualified registry, or a qualified EHR product. Group practices that wish to take advantage of this option will be required to participate in the PQRI group practice reporting option. Practices are required to submit a self-nomination letter to CMS, requesting to participate in the 2010 PQRI group practice reporting option.
To date, the Drug Enforcement Agency has not authorized e-prescribing of controlled substances. Those who prescribe controlled substances have been hesitant to adopt the technology because of workflow issues and the burden of using two processes (electronic and written) for generating a prescription. This limitation, however, was taken into consideration when CMS established the 2010 criteria for the program.
Will you participate?
Based on a small sample survey of AAOS members, nearly half of respondents plan to participate in the incentive program. Barriers such as cost to implement an e-prescribing system in their practice and the time to train physicians and staff still exist, however.
The AAOS has a host of educational resources that may help members who are interested and plan to participate, but are not sure where to start. For more information on e-prescribing, visit www.aaos.org/quality
Toya M. Sledd, MPH, MBA, is the clinical quality improvement coordinator in the department of research and scientific affairs. She can be reached at firstname.lastname@example.org