“Requirements and Penalties UPDATE: CMS e-Prescribing Incentive ”

1. “Requirements and Penalties UPDATE:CMS e-Prescribing Incentive” Jonathan Kolarik, RN, MBA, OFMQHIT Director

2. Program Overview • Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) includes an incentive program for EPs who are successful electronic prescribers. • This incentive program began on January 1, 2009, and is separate from Physician Quality Reporting System program. • Reporting periods are for calendar year 2009-2013. • There is not an application process.

3. Eligible Professionals Physicians • • Doctor of Medicine• Doctor of Osteopathy• Doctor of Podiatric Medicine• Doctor of Optometry• Doctor of Oral Surgery• Doctor of Dental Medicine• Doctor of Chiropractic Therapists • • Physical Therapist• Occupational Therapist• Qualified Speech-Language Therapist Practitioners • • Physician Assistant• Nurse Practitioner• Clinical Nurse Specialist• Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant)• Certified Nurse Midwife• Clinical Social Worker• Clinical Psychologist• Registered Dietician• Nutrition Professional• Audiologists 

4. “Payment Adjustments” (Penalties) for NOT e-Prescribing: • 2012 – 1% reduction in Medicare reimbursement • 2013 – 1.5 % total reduction • 2014 – 2% total reduction

5. Avoiding “Payment Adjustments” • Avoiding the 2012 eRx payment adjustment • EPs must report 10 eRx events with appropriate G Code via claims by June 30th 2011. • Avoiding the 2013 eRx payment adjustment • EPs must report 15 additional eRx events with appropriate G Code by December 31st 2011.

6. Exemptions • Provider does not have Prescriptive Privileges • Provider does not have at least 100 cases containing an encounter code in the measure denominator from the list of eligible codes • Eligible professionals who register to participate in the 2011 Medicare or Medicaid EHR Incentive Program and adopt certified EHR technology; • Inability to electronically prescribe due to local, state, or federal law or regulation (e.g., controlled substances); • Limited prescribing activity; or • Insufficient opportunities to report the electronic prescribing measure due to limitations in the measure’s denominator.

7. Eligible Encounter Codes If you bill these codes, you are required to e-prescribe……..

8. How to Participate • 1. Claims-based reporting • 2. Registry-based reporting • 3. EHR-based reporting

9. Successful Reporting for 2011 • The eRx G-code must be reported: -on the claim(s) with the billing code(s) that represent the eligible encounter -for the same beneficiary -for the same date of service (DOS) -by the same eligible professional (individual NPI) who performed the covered service as the payment codes. This is usually ICD-9-CM, CPT Category I or HCPCS codes.

10. Successful Reporting Include a single quality-data code (eRx G-Code) • G8553 “At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.”

11. Hardship Exemption • Previously handled via G-Code • NOW…. • Web-based tool for request, found here: https://www.qualitynet.org/portal/server.pt/community/communications_support_system/234 • Final submission deadline for hardship submission is 11/1/2011

12. Electronic Submission • The eRx G-code should be submitted in the SV101-2 “Product/Service ID” Data Element on the SV1 “Professional Service” Segment of the 2400 “Service Line” Loop. • It is also necessary to identify in this segment that an HCPCS code is being supplied by submitting the HC in data element SV101-1 within the SV1 “Professional Service” Segment. • Diagnosis codes are submitted at the claim level, Loop 2300, in data element HI01, and if there are multiple diagnosis codes, in HI02 through HI08 as needed with a single reference number in the diagnosis pointer. • In general for group billing, report the NPI for the rendering provider in Loop 2310B (Rendering Provider Name, claim level) or 2420A (Rendering Provider Name, line level), using data element NM109 (NM108=XX).

13. Paper-Based Submission • Paper-based submissions are accomplished using the CMS-1500 claim form (version 08-05) as described in the next slide. • Relevant ICD-9-CM diagnosis codes are entered in Field 21. • Service codes (including CPT, HCPCS, CPT Category II and/or G-codes) with any associated modifiers are entered in the appropriate field for group and individual practices.

14. CMS 1500 Claim Electronic Prescribing Example

15. Process Variables • Submission processes will vary based upon: • Software • Clinical versus claims capture • Third party Gateway software • Automated versus Manual G Code entry • Paper versus Electronic Submission

16. Current Incentive Programs • PQRS • eRx • EHR * Providers participating in PQRS cannot earn both an eRx Incentive and an EHR Incentive in the same year if the Provider elects to receive their EHR incentive through Medicare.

17. Free or Low Price eRx Products • https://erxnowregistration.allscripts.com/ • http://www.rxnt.com/

18. How Can We Work Together? • OFMQHIT Workflow Analysis • OFMQHIT Meaningful Use Gap Report • OFMQHIT Risk Analysis for Security/Privacy • OFMQHIT close relationships with hardware and software vendors • OFMQHIT ongoing connectivity with Beacon, OHCA, CMS, OHIET, and ONC • OFMQHIT EHR Optimization

19. Hospital and Provider Office Services • Meaningful Use Assessment and Gap Analysis • Practice & Workflow Assessment and Design • EHR Optimization • Project Planning • Go-Live Support • Post Go-Live Practice Assessment • IT Security and Privacy Assessment • E-Prescribing Analysis

20. Helpful Links • https://www.cms.gov/ERxIncentive/01_Overview.asp#TopOfPage • Several detailed handouts and a quick survey will be provided via email after the presentation

21. Questions? Thank YouJonathan Kolarik RN MBAofmqhit@ofmq.com 405-302-3286 www.ofmqhit.com