Avoid EHR Penalties with These Proposed Additional Exemptions

 Posted on 07. Jul, 2011 by rpandit in Hot Coding Topics, Provider News Check whether your group might fall into one of four new categories. The push toward e-prescribing is in full swing, with physicians possibly being subjected to a one percent paym...

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Avoid EHR Penalties with These Proposed Additional Exemptions

Check whether your group might fall into one of four new categories.

The push toward e-prescribing is in full swing, with physicians possibly being subjected to a one percent payment hit on CMS claims in 2012 if you don’t successfully participate in e-prescribing this year (and larger hits in 2013 and 2014). If your physicians haven’t yet met e-prescribing criteria, take hope: CMS has proposed four additional ways that eligible professionals (EPs) can potentially avoid the adjustment in 2012.

The imminent penalty for physicians who don’t e-prescribe “has created quite a bit of concern about circumstances where doctors will potentially be penalized, not necessarily because of failure to electronically prescribe, but more so because of some complexities with regard to the measurement,” said Michael Rapp, MD, JD, director of the quality measurement and health assessment group at CMS, during a May 26 CMS Open Door Forum.

Previously, physicians could apply for a hardship exemption only if they could prove a lack of access to the internet in their area or limited access to pharmacies that accepted electronic prescribing. Under the new proposal, EPs would be eligible to request a hardship exemption that CMS would determine on a case-by-case basis if they meet one of the following additional four criteria, Rapp said.

1. Registering With Intent to Adopt EHR Technology
Practitioners who intend to start participating in the HER (Electronic Health Record) Incentive Program might still be getting their technology in place, so they may not have e-prescribed ten times within the first six months of 2011, as is required to avoid the penalty. The new proposal aims to offer those practices a potential exemption.

2. Prescribing Meds That Legally Cannot Be Electronically Transmitted
Many state, local, or...

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Put Your ePrescribing Knowhow Into Meaningful Use

Get your system moving before June 30th or you’ll pay the price.

If you do not have an electronic prescribing (ePrescribing or eScribing) system yet in place, or have not integrated one into your electronic medical record (EMR) system, you better get a move on it. You only have until June 30, 2011 to submit at least ten claims to Medicare demonstrating that you are a successful eScriber for 2011. Otherwise, you are at risk of not only losing the bonus in 2011 but according to the rulemaking for 2011, also facing penalties assessed, reducing your Medicare fee schedule by 1 percent in 2012.

With limited time, it is smart to consider a stand-alone internet based system which you can implement relatively easy. You could get this system up and running right away, at a low cost, with simplified a implementation timeline and without depending on your electronic health record (EHR) selection and implementation which is both much more extensive, costly and more complicated to implement.

If you’re still asking, “Can our practice afford not to adopt ePrescribing?” Then, the answer is NO. Today you need to start doing something.

Background: eScribing is part of Centers for Medicare and Medicaid Services’ (CMS) incentive program called the Physician Quality Reporting System (PQRS). PQRS offers incentives to practices that meet CMS-set goals for the implementation and practice of electronic prescription on a regular basis. The system was designed with “a carrot and a stick”. While we have been enjoying the “carrot” for the past few years, the “stick is on the cusp of being implemented as of June 30th per the 2011 Rulemaking. CMS will pay you when you implement eScribing in 2011 (a 1 percent bonus), it will penalize you when you don’t put it into practice, a 1percent penalty...

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CMS: Prove Your Exemption From the E-Prescribing Penalty With New G Codes

Even if you don’t have prescribing privileges, you can rest assured now as CMS will not cut your pay as a penalty for failing to comply with the new e-prescribing incentive program.

As you are probably aware, starting in 2012, you may be subject to a one percent payment adjustment on your Part B pay if you don’t successfully participate in e-prescribing this year. In 2013, that payment adjustment will go up to 1.5 percent, and in 2014 it will rise to two percent, CMS’s Daniel Green, MD noted on a Feb. 15 CMS-sponsored call.

“To earn an incentive in 2011, an eligible professional must e-prescribe 25 times during the year, ten of which must be in the first six months,” Green said. “If they are a successful e-prescriber during the calendar year, they not only would avoid the 2012 payment adjustment, they would get a one percent 2011 payment incentive, and they would be exempt from the 2013 payment adjustment,” he explained.

“Earning an incentive in 2011 does not necessarily exempt the eligible professional or group practice from a payment adjustment in 2012,” Green explained.

How to Avoid the Adjustment

CMS reps said that they’ve been flooded with calls about the 2012 payment adjustment, and described ways that you can avoid the adjustment if you qualify.

Not eligible to prescribe: If you are not a physician, nurse practitioner, or physician assistant between Jan. 1 and June 30, 2011, you can avoid the e-prescribing penalty. In addition, if you don’t have prescribing privileges at least once on a claim between Jan. 1 and June 30, 2011, you should append G8644 (Eligible professional does not have prescribing privileges) at least once before June 30 to ensure that your MAC knows you are not subject to the penalty, said CMS’s Michelle...

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EHR Incentive Program Enrollment Starts Soon

CMS clears up flu shot coding confusion.

You’ve heard the advantages of participating in CMS’s Electronic Health Record (EHR) Incentive Program (including $44,000 per-physician bonus incentives over a five-year period), but you may not be sure how to enroll.

CMS staffers cleared up that confusion during an Oct. 5 open door forum, where CMS’s Rachel Maisler indicated that you must register on CMS’s EHR incentive program’s Web site, which will open in January 2011 for the Medicare program.

In addition, you must be enrolled in CMS’s PECOS system and have an NPI, and you must use certified EHR technology. You can find details on how to determine which EHR systems are certified on www.healthit.hhs.gov.

Key dates: During the call, CMS reps also announced important dates involved in EHR participation. “Attestation, which is how you will report the objectives and measures for meaningful use and clinical quality measures, will begin in April of 2011, and we expect the first payments will be made in May of 2011,” Maisler said.

Look for Combined Flu Shot

Flu vaccine: Now that the H1N1 immunization is part of the regular flu vaccine, a caller asked the CMS officials whether a new code will be developed to describe the combined flu shot, but CMS officials noted that no such code will be issued.

“We’re continuing to use the same codes as last year, and my understanding is the H1N1 is part of the regular flu vaccine this year, so you’d bill what the appropriate flu vaccine code is,” said CMS’s Amy Bassano, during the call. High-dose flu vaccine code 90662 (Influenza virus vaccine, split virus, preservative free, enhanced immunogenicity via increased antigen content, for intramuscular use) has been added to the roster of codes that can be billed to Medicare, Bassano confirmed.

RACs: Another caller...

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