E-Prescribing for Medicare Patients on Orlando Medical News

E-Prescribing for Medicare Patients

By: LYNNE JETER

Leslie Witkin Explains Bonus Potential Outweighed By Ultimate Penalty and Other Nuances

The good news is that e-prescribing, as described in the Medicare Improvements for Patients & Providers Act of 2008 (MIPPA) passed by Congress last July, provides for a bonus for compliance initially. The bad news is that it may be outweighed by a penalty for not successfully prescribing.

According to the legislation, a bonus for successful e-prescribing for 2009 and 2010 is 2 percent each year of all covered allowed Part B amounts, 1 percent for 2011 and 2012, and 0.5 percent for 2013.

On the other hand, the penalties for not e-prescribing at all or not successfully e-prescribing are 1 percent in 2012, making Medicare allowed amounts 99 percent of the fee schedule amount; 1.5 percent in 2013, or Medicare allowed amounts of 98.5 percent of the fee schedule amount; and 2 percent in 2014 and beyond, or Medicare allowed amounts of 98% of the fee schedule amount. The fee reductions beginning in 2012 would be based on analyzing claims data from prior years. The first year for data review will not be before 2010.

The Orlando Medical News asked Leslie Witkin, president of Physicians First Inc. in Orlando, to explain the complexities of the e-prescribing elements of this new legislation.

What is "successful" e-prescribing?

E-prescribing is defined as entering a prescription for a medication into an automated data entry system that generates a prescription electronically instead of handwriting the prescription on paper.

You must have a "qualified" e-prescribing system, which generates a medication list; provides information on formulary or tiered formulary medications, patient eligibility and authorization requirements received electronically from the patient's drug plan; provides information on lower cost alternatives; and selects medications, transmits prescriptions electronically and conducts safety checks. Those safety checks include automated prompts that offer information on the drug being prescribed, potential inappropriate dose or route of administration of the drug, drug-drug interactions, allergy concerns, and warnings/cautions.

How do you report e-prescribing to qualify for the bonus?

Reporting is accomplished through the submission of your claims. Measure No. 125 from PQRI (Physician Quality Reporting Initiative) is the e-prescribing measure for claims-based reporting purposes. For the e-prescribe bonus potential, this measure will be removed from PQRI and used exclusively for e-prescribe analysis.

The measure is intended to be reported for all eligible Medicare patients. If you render and bill for one of the following codes (called denominator codes), then you must also include a "numerator" code in your claim to report the e-prescribing measure. "Denominator" codes are 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, G0101, G0108, and G0109.

"Numerator" codes are currently "G" codes. The current "G" codes are:

G8443. The prescriptions generated during the patient encounter were generated using a qualified system.
G8445. You have a qualified system, but no prescriptions were generated during the patient visit.
G8446. You have a qualified system, but some or all of the prescriptions during the encounter were handwritten or phoned in due to one of the following: required by state law (such as narcotics), patient request ( such as patient going away for winter), or your system is currently inoperable.

To qualify for a bonus or not to be penalized, you must report the measure on at least 50 percent of eligible patients (unlike the 80 percent required for PQRI). The CPT codes that make up the denominator codes must account for at least 10 percent of the provider's total allowed charges for Medicare Part B covered services. MIPPA does allow, at the discretion of the Secretary of Health and Human Services, to change the requirement for successful reporting based on the number of Part D prescriptions. If this happens in the future, the Part D data would be used in lieu of your having to report through the claims-based system.

What e-prescribing system should you have in place?

The Center for Medicare and Medicaid Services (CMS) does not endorse any product, but suggests you view the website for SureScripts to see if your current system has and/or is certified to perform the required functions.

SureScripts does not offer e-prescribe systems. They allow systems to connect to the Pharmacy Health Information Exchange System. The connection is at no charge.

Your expenses for e-prescribing are incurred through your vendor or a standalone e-prescribe vendor, usually at a per provider cost for the system and other relevant system products. You do not have to have an electronic medical record (EMR) to perform e-prescribing.

Several organizations are supporting the following website to review your current status and possible needs, solutions for e-prescribe: http://www.GetRxConnected.com/.