|
|
|
|
|
|
|
|
|
|
|
|
|
|

HIT INCENTIVE PROGRAMS
|
| |
E-PRESCRIBING
|
|
|
| Medicare and E-Prescribing |
|
- E-Prescribing is the electronic transmission of prescription or prescription-related information between a prescriber, dispenser, pharmacy benefit manger, or health plan either directly or through an intermediary, including an e-prescribing network. It includes, but is not limited to, two-way transmissions between the point of care and the dispenser. It is important to note that computer-generated faxing does not qualify as an e-prescribing incentive.
|
- E-Prescribing has many potential benefits including:
- Increased patient safety resulting from harmful interaction checks and alerts
- Fewer medication errors through computerized transmission of legible prescriptions directly to the pharmacy
- Fewer phone calls between physician and pharmacy for clarification and improved fomulary compliance, which may result in higher patient compliance.
|
- The Medicare Improvements for Patients and providers Act of 2008 (MIPPS) created an e-prescribing (eRX) reporting incentive the pays successful electronic prescribers 2% of Medicare billing starting in January 2009.
- The e-prescribing initiative is a modified version of Medicare's Physician Quality Reporting System (PQRS, formerly PQRI) Measure 125.
- Physicians do not need to participate in PQRS to take part in the e-prescribing incentive program.
- Physicians may participate in both initiatives and receive separate incentive payments.
- The incentive begins to decline in 2011, and a penalty beings in 2012 for physicians not utilizing electronic prescribing.
|
- Under the eRx Incentive Program, covered professional services are those paid under the Medicare Physician Fee Schedule (PFS). To the extent that eligible professionals are providing services which are paid under the PFS, those services are eligible for eRx Incentive Program.
|
- Eligible professionals could have reported the eRX measure at any time throughout the 2012 program year of January 1 - December 31, 2012 to be incentive eligible.
|
- To be exempt from the 2013 eRX payment adjustment, eligible professionals must have reported 10 eRX events from Janurary 1, 2012 - June 30, 2012. If the physician succesfully received an eRX incentive payment for 2011, he/she will automatically be exempt from the 2013 eRX payment adjustment.
|
- In these instances, providers may be eligible but unable to participate in the incentive program:
- Professionals paid under or based upon the PFS billing Medicare Carriers/ Medicare Administrative Contractors (MACs) who do not bill directly.
- Professionals paid under the PFS billing Medicare fiscal intermediaries (FIs) or MACs. The FI/MAC claims processing systems currently cannot accommodate billing at the individual physician or practitioner level
- Critical access hospital (CAH), method II payment, where the physician or practitioner has reassigned his or her benefits to the CAH. In this situation, the CAH bills the regular FI for the professional services provided by the physician or practitioner.
- All institutional providers that bill for outpatient therapy provided by physical and occupational therapists and speech language pathologists (for example, hospital, skilled nursing facility Part B, home health agency, comprehensive outpatient rehabilitation facility, or outpatient rehabilitation facility). This does not apply to skilled nursing facilities under Part A
|
|
|
| Top of Page |
|
| How to Get Started |
|
|
|
|
| Top of Page |
|
| |
|
| Implementation and Use |
|
- There are two types of systems:
- A system for eRX only (stand-alone)
- An electronic Health Record (EHR) system with eRX functionality.
- Regardless of the type of system used, to be considered "qualified" it must be based on all of the following capabilities:
- Generating a complete active medication list incoporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs) if available.
- Selecting medication, printing prescriptions, electronic transmitting prescriptions, and conducting all alerts.
- Providing information related to lower cost, therapeutically appropriate alternatives (if any).
- Providing information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received elecronically from the patient's drug plan (if available).
|
|
|
| Top of Page |
|
| Successful Reporting |
|
- Use any of the following three reporting options:
- Claims-based reporting of the eRX measure using G-code (G8553)
- Registry-based reporting using a CMS-selected registry to submit 2011 data to CMS during the first quarter fo 2012.
- EHR-based reporting using a CMS-selected electronic health record product, submitting 2011 data to CMS during the first quarter of 2012.
- Physicians do not need to sign up to participate; submission of the e-prescribing G-code indicates participation.
- Physicians must report that an e-prescription was generated for a minimum of 25 unique patient visits.
- When presented with an applicable case, physicians can report on the e-prescribing measure with 2 steps liste below:
- Step 1: Bill under one of the following denominator codes (CPT or HCPCS):
|
| 90801 |
90802 |
90804 |
90805 |
90806 |
90807 |
90808 |
90809 |
| 90862 |
92002 |
92004 |
92012 |
92014 |
96150 |
96151 |
96152 |
| 99201 |
99202 |
99203 |
99204 |
99205 |
99211 |
99212 |
99213 |
| 99214 |
99215 |
99304 |
99305 |
99306 |
99307 |
99308 |
99309 |
| 99310 |
99315 |
99316 |
99324 |
99325 |
99326 |
99327 |
99328 |
| 99334 |
99335 |
99336 |
99337 |
99341 |
99342 |
99343 |
99344 |
| 99345 |
99347 |
99348 |
99349 |
99350 |
G0101 |
G0108 |
G0109 |
|
- Step 2: If an electronic prescription is generated, report on the claim form G-code G8553 for the numerator for at least 25 unique visits for Meicare Part B patients during the reporting period.
- G8553 indicates that at least on prescription created during the encounter was generated and trasmitted electronically using a qualified e-prescription system
|
| USEFUL LINKS
|
|
|
| Top of page |
|
| |
|
| Common Mistakes That Can Result in a Penalty |
|
Below are some quick tips to help you and your office staff bill appropriately while participating in the eRx Incentive Program
- If all billable services on the claim are denied for payment by the Carrier or A/B MAC, the eRx G-code will not be included in eRx Incentive Program analysis
- Be sure to place the individual physician’s National Provider Identifier (NPI) next to each line item -Place a charge of $0 or $0.01 next to the line item, never leave the charge field blank
- Check with your clearing house to make sure how the charge should appear so the G8553 code will not be stripped in the process
- Once the claim is processed be sure to check the Remittance Advice (RA)/Explanation of Benefits (EOB) for the denial code N365
- This is your indication that the eRx G-code was received into the National Claims History
- N365 can indicate that the claim will be used in calculating incentive eligibility.
Avoiding Billing Pitfalls – Tips for Success Below are some quick tips to help you and your office staff bill appropriately while participating in the eRx Incentive Program
- If all billable services on the claim are denied for payment by the Carrier or A/B MAC, the eRx G-code will not be included in eRx Incentive Program analysis
- Be sure to place the individual physician’s National Provider Identifier (NPI) next to each line item -Place a charge of $0 or $0.01 next to the line item, never leave the charge field blank
- Check with your clearing house to make sure how the charge should appear so the G8553 code will not be stripped in the process
- Once the claim is processed be sure to check the Remittance Advice (RA)/Explanation of Benefits (EOB) for the denial code N365
- This is your indication that the eRx G-code was received into the National Claims History
- N365 can indicate that the claim will be used in calculating incentive eligibility.
|
|
|
| Top of Page |
|
| |
|
| INCENTIVE PROGRAM |
|
| INCENTIVES |
|
|
|
|
| Top of Page |
|
| Adjustments / Penalties |
|
- Checking for Penalty Adjustment on your Claims
- If you are receiving the 2012 eRx payment adjustment you will see the indicator “LE” on your Remittance Advice/EOB for all Medicare Part B services rendered from January 1–December 31, 2012.
- The remittance advice will also contain the following Claim Adjustment Reason Code (CARC) and Remittance Advice Remark Code (RARC):
- CARC 237 – Legislated/Regulatory Penalty. At least one Remark Code must be provided (may be comprised of either the NCPDP Reject Reason Code, or Remittance Advice Remark Code that is not an ALERT).
- RARC N545 – Payment reduced based on status as an unsuccessful e-prescriber per the Electronic Prescribing (eRx) Incentive Program.
- Physicians who successfully report 10 claims via the G8553 code from January 1, 2012 through June 30, 2012 will be able to avoid the 1.5% penalty to their Medical Part B services provided January 1, 2013 through December 31, 2013.
If you were a successful electronic prescriber in 2011, you will also meet criteria to avoid the 1.5 penalty from January 1, 2013 through December 31, 2013
- Physician must have reported e-prescribing via claims using G-Code G8553 on at least 10 unique Medicare encounters by June 30, 2011, to avoid the penalties in 2012 (1% of medicare Part B claims).
- Physician also must have reported at least 25 times by December 31,2011, to qualify for a 1% bonus of Medicare Part B claims and to prevent the pnealty in 2013.
- Final rule on 2012 Medicare e-precribing penalty HCMS Physician Newsletter, Sept 15, 2011
- USEFUL LINKS
- AMA-How to avoid 2013 e-prescribing penalties 3 page guide created by the AMA on how to avoid the 1.5% 2013 e-prescribing penalty by either complying with the e-prescribing reporting requirements or applying for a hardship exemption
- The HIT Parade - 45 days left to avoid a 1.5% 2013 eRx penalty HCMS Physician Newsletter, May 15, 2012
- The HIT Parade - 3 Medicare deadlines on June 30, 2012 HCMS Physician Newsletter, May 1, 2012
- The HIT Parade - Avoid 1.5% 2013 eRx penalty HCMS Physician Newsletter, Apr 15, 2012
- The HIT Parade - Avoid 1.5% 2013 eRx penaltyHCMS Physician Newsletter, Apr 1, 2012
- The HIT Parade - Avoid the 2013 eRx penalty HCMS Physician Newsletter, Sept 1, 2011 issue
- Final rule on 2012 Medicare e-precribing penalty HCMS Physician Newsletter, Sept 15, 2011
- eRX penalty exemption - Medicare Corner,HCMS Physician Newsletter, October 1, 2011.
|
|
|
| Top of Page |
|
| Exemptions |
|
The deadline for physicians to request an exemption to the 2013 penalty is: Janurary 31, 2013
- The original deadline to apply on line for a 2013 e-prescribing (eRx) hardship exemption to avoid a 1.5% penalty was January 1, 2012 - June 31, 2012.
- The original deadline has been extended and physicians will have a second chance from apply for 2013 eRx hardship exemption from November 1, 2012 - January 31, 2013.
- Physicians meeting any one of the criteria listed below can apply for a hardship exemption on-line with Medicare from November 1, 2012 through January 31, 2013.
- Physician cannot electronically prescribe due to local, state, or federal law or regulation (e.g., you prescribe controlled substances).
- Physician prescribes less than 100 prescriptions, this means all prescriptions not just Medicare between Jan. 1 and June 30.
- Physician practice is in a rural area without high-speed Internet access
- Physician practice is in an area without sufficient available pharmacies for electronic prescribing.
Physician meaningfully using their EHR will automatically be exempt from the 2013 1.5% eRx penalty
- Physicians participating in the Medicare or Medicaid Electronic Health Record (EHR) Incentive Programs may qualify for one of the two criteria listed below. Medicare will check the EHR Incentive Programs Registration and Attestation Web Site for qualifying physicians and automatically exempt them.
- To qualify for the exemption, physician should be meaningfully using their EHR for 90 days (if attesting for the first year) or for a full year (for all subsequent year) at some point during January 1, 2011 – June 30, 2012 and attest to this by January 21, 2013.
- Meaningful use means physicians must be able to use their EHR and enter all information required to meet the 15 core criteria and 5 menu criteria for at least 80% of their patients.
- Physicians who are not yet using but are in the process of adopting an EHR must register for the EHR Incentive Program by January 21, 2013. Physician must enter their entire EHR Certification Number in to the CMS EHR Certification ID field on the Registration and Attestation Web Site to receive this hardship.
Meeting exemption criteria or requirements to avoid the 2013 1.5% eRx penalty does not mean physicians will automatically receive the 0.5% 2013 eRx incentive
- Meeting anyone of the criteria above will exempt physicians from the 2013 1.5% eRx penalty. However, to receive a 0.5% 2013 eRx incentive, physicians must still report 25 eRx events using the G8553 claims code with dates of service January 1-December 31, 2013, to reach the Medicare claims database by February 22, 2014.
- The eRx event will only count towards the 25 if the G8553 is associated with these billing codes: 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, and G0109.
Qualifying for exemption-Physicians who did not succesfully e-prescribe 10 prescriptions and report it on a claim form with G-code G8553 by June 30, 2012, are subject to a 1.5% penalty on their Medicare Part B services starting January 1, 2013. However, thanks to advocacy from the Texas Medical Association (TMA), the American Medical Association (AMA) and others. On August 31, 2011, CMS announced four new harship exemptions in addition to the exisiting two that physicians could claim to prevent the penalty:
How to request an exemption
- 2013 Exemption dealine will be Janurary 31, 2013
- 2012 Exemption deadline was November 8, 2011
- Use the new CMS provider Web site:
- Quality Reporting Communication Support Page, to enter the hardship exemption request and supporting rationales.
- Always choose the Individual Eligible Professional option, even if you are filing hardship ememptions for several physicians in the same practice
- The electronic form must be filled out for each physician with the Practice Tax Identification Number (TIN) and the National Provider identifier (NPI) of the individual physician
- Contact the Quality Net Help Desk for any questions
- The Quality Net Help Desk
- 7 a.m. - 7 p.m. CT (Monday - Friday)
- E-mail: qnetsupport@sdps.org
- Phone: (866) 288-8912
- TTY: (877) 715-6222
- Fax: (888) 329-7377
- Group practices participating as GPROs:
- The group practice option is only for those practices that have signed up or have been choosen my CMS to participate in the group practice pilot program
- Group practices selected for and participating in the 2012 GPRO I or II reporting option who wished to submit a 2013 exemption request must have submitted a letter that was postmarked no later than November 1, 2011 to:
- USEFUL LINKS
- 3 Medicare deadlines on June 30, 2012 - HIT Parade, HCMS Physician Newsletter, May 1, 2012
- File now for 2013 eRx harship exemption - HIT Parade, HCMS Physician Newsletter, April 15, 2012
- Avoid 1.5% 2013 E-Prescribing Penalty-Hit Parade, HCMS Physician Newsletter, April 1, 2012
|
|
|
| top of page |
|
| |
|
MEDICARE & MEDICAID EHR INCENTIVE PROGRAMS
|
|
| General |
|
- CMS EHR Incentive Programs - In 2009, the Health Information Technology for Economic and Clinical Health Act (HITECH Act) established criteria for Medicare and Medicaid participating physicians to receie financial incentives for using EHRs in a meaningful manner. Implementation of certified EHR technology will enable physicians to take advantage of Federal Stimulus funding of up to $44,000 in additional Medicare payments and up to $63,750 in additional Medicaid payments between 2011 and 2015.
- Registration for Incentive Programs
- Attestation for Incentive Programs
- To receive the incentive payment physicians must "attest" to meaingfully using their EHR. This means physicians have to go on the website and report yes/no as to weather they have completed the required measurements.
- CMS Meaningful Use Attestation Calculator - This online tool allows physicians to test whether or not they would successfully demonstrate meaningful use for the EHR Incentive Programs.
- CMS Attestation Webinar a 20 minute YouTube video providing a step by step demonstration on how to use the attestation system and answer common questions about attestation for the Medicare Program
- TMA-Meaningful Use Achievement Toolkit (NextGen, GE/Centricity, e-MDs, Greenway Medical) - EHR product specific screenshots and video demonstrations giving detailed demonstrations on meeting any one of the 25 meaninful use criteria
- HELPFUL ARTICLES AND FACTSHEETS
- Medicare and Medicaid EMR Incentive Comparison TMA comparison chart
- Can I benefit from these three incentive programs at once? TMA discuss PQRS, e-RX, and EHR incentive program
- CMS Tip Sheet - Comparison of EHR, E-Prescribing, and PQRS incentives
- Established EMR users - This article is for you! Meet meaningful use and receive bonus payment. HCMS Physician Newsletter, Nov 15, 2010 issue.
- CMS flow chart to help determine eligibility for incentive programs
- HIT Parade - Texas Medicare, Medicaid EHR incentives reach $30 million HCMS Physician Newsletter, Nov 1, 2011 issue
- HIT Parade - Successful reporting of clinical quality measures (CQMs) HCMS Physician Newsletter, Oct 1, 2011
- HIT Parade - Education and Assistance. TMA HIT hotline, what EHR incentive programs are right for my office? What steps are required to earn EHR incentives? HCMS Physician Newsletter, Aug 2011 issue.
- Registration for the Medicare and Medicaid EHR incentive programs is now open HCMS Physician Newsletter, February 1, 2011 issue
- Health Information Technology Policy Committee advises HHS on Stage 2 Meaningful use (Jan 12, 2011)
- CMS EHR incentive programs milestone timeline
- CMS EHR Incentive Programs Main Page
|
|
|
top of page
|
|
| Medicare |
|
- Registration for Incentive Programs
- CMS Registration User Guide for Medicare Eligible Professionals
- CMS Registration and Attestation System - Secure log-in page to register and participate in the Medicare & Medicaid EHR Incentive Program
- Attestation for Incentive Programs
- CMS Web site on Attestation
- CMS Attestation User Guide for Medicare Eligible Professionals
- CMS Eligible Professional Attestation Worksheet
- CMS Attestation Webinar a 20 minute YouTube video providing a step by step demonstration on how to use the attestation system and answer common questions about attestation for the Medicare Program
- CMS 2012 e-Prescribing Incentive Requirements
- HIT Parade - Attestation worksheet for Medicare EHR incentive program HCMS physician Newsletter, Oct 15, 2011 issue - for help to log meaningful use measures
- HIT Parade - EHR incentive Q&A - I see patients in multiple locations, so should I include all patient encounters in the denominator? HCMS physician Newsletter, Sept 1, 2011 issue.
- Medicare EHR incentives different for participation in Medicare Advantage Plans HCMS physician Newsletter, February 1, 2011
- CMS tip sheet of Medicare incentives and meaningful Use of EHRs
- CMS MLN Matters SE1111 on the EHR Medicare incentive payment process
|
|
|
top of page
|
|
| Medicaid |
|
- Registration for Incentive Programs
- CMS Registration User Guide for Medicaid Eligible Professionals
- CMS Registration and Attestation System - Secure log-in page to register and participate in the Medicare & Medicaid EHR Incentive Program
- Attestation for Incentive Programs
- Medicaid professionals will attest through the state. (TMHP)
- TX Medicaid EHR Incentive Program: Deadlines for 2012 Participation - Info from TMA (Medicaid)
- Texas Medicaid EHR incentive payments begain in May 2011 HCMS Physician Newsletter, March 1, 2011 issue
- How to calculate patient volume for the Medicaid EHR incentive TMA Calculation for TX Medicaid Program
- Overview of medicaid Incentives and Meaningful Use
- TMHP (Texas Medicaid) website on HIT and the Medicaid Incentive Program
- CMS Website on Medicaid State Information incentive provisions, fact sheet, etc.
|
|
|
top of page
|
|
| |
|
| Meaningful Use |
|
| STAGE 1 |
|
- "Meaningful Use" means physicians need to show their certified EHR meets specific criterias that can be measured and reported (e.g., able to record demographic information, able to
- These criteria are expected to be adopted in 3 stages, currently we are in stage 1, stage 2 rules have been proposed but not finalized. Stage 3 is expected to be implemented in 2015.
- For stage 1, physician must meet 20/25 meaningful use objective. 15 are core objective which means that all participating physicians must meet these objectives. The remaining 5 objective can be choosen from a list of 10 menu set objectives.
- HCMS Incentive Calculator HCMS has developed a calculator to assist our members in evaluating the Medicare incentives. The calculator gives you an opportunity to see how penalties and the incentives will affect you in different scenarios new 2012 (Members only)
- TMA-Meaningful Use Achievement Toolkit (NextGen, GE/Centricity, e-MDs, Greenway Medical) - EHR product specific screenshots and video demonstrations giving detailed demonstrations on meeting any one of the 25 meaninful use criteria
- Meaningful use glossary and requirements table for 2011-2012 (AMA) (Medicare/Medicaid)
- Meaningful Use Measures Comparison Grid AMA Helpful grid comparing stage 1 and stage 2 core and menu measures required for meaningful use reporting
- Stage 1 EHR Meaningful Use Measures This document created by The Centers for Medicare and Medicaid Services (CMS) lists all 25 objectives specified in the stage 1 rules and also give specific information on what is required to meet each objective.
- Changes to Stage 1 Meaningful Use Measures as part of the published final rule on Stage 2 Meaningful Use, CMS also made changed to the Stage 1 meaingful use objectives, measures, and exclusion for physicians. These changes will not take effect until calendar year 2014 and will be optional in 2013. Thid PDF document gives a summary of these changes.
|
|
|
| top of page |
|
| STAGE 2 |
|
- CMS Tip Sheet on Meaningful Use Stage 2 CMS overview of the specfic Stage 2 criteria physicians must meet in order to continue to participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.
- Stage 1 vs. Stage 2 Comparison Table a table comparing the specific meaures physicians must meet for both Stage 1 and Stage 2 of the Medicare and Medicaid EHR Incentive Program.
- CMS Stage 2 Web Page click to go to the CMS Web Page that gives an overview of the new Meaingful Use Stage 2 final rule.
- Meaningful Use Stage 2 Final Rule click to see published final rule.
- RULES AND COMMENTS
- HELPFUL ARTICLES
- HELPFUL ORGANIZATIONS & WEBSITES
|
|
|
| top of page |
|
| MEANINGFUL USE AUDITS |
|
- Anyone who receives incentives could be audited by The Centers for Medicare & Medicaid Services (CMS).
- CMS has engaged The Garden City, N.Y., accounting firm Figliozzi & Co. to conduct these audits.
- Although these audits are not expected to involve site visits, the firm is sending letters asking for documentation supporting the meaningful use attestation.
- The four type of documentation the firm is asking for includes:
- Documentation from the Office of the National Coordinator for Health IT showing use of a certified electronic health record (EHR) system for meaningful use attestation;
- Information about the method used to report emergency department admissions (for hospitals);
- Documentation that the attestation for the core set of meaningful use criteria was completed; and
- Documentation that the required number of menu set meaningful use objectives was completed
- Physicians selected for audits will have two weeks to submit their documentation.
- CMS is advising all physicians who are receiving incentives for meaningful use to retain all supporting documentation for six year.
|
|
|
top of page
|
|
| |
|
|
Last Updated 2/25/2013 -
|
|
1515 Hermann Drive Houston, TX 77004-7126
Ph: (713) 524-4267, Fax: (713) 526-1434
Copyright 1999-2012 Harris County Medical Society All Rights Reserved
Contact Us Site Map
|
|