To avoid e-prescribing penalties, eligible professionals must meet e-prescribing reporting requirements, qualify for an exclusion or submit for a hardship exemption by June 30, 2012
In 2009, CMS implemented the E-Prescribing Incentive Program, which is a program that uses incentive payments and payment adjustments to encourage the use of e-prescribing systems.
From calendar year (CY) 2012 through 2014, a payment adjustment that increases each calendar year will be applied to an eligible professional's Medicare Part B Physician Fee Schedule (PFS) covered professional services for not becoming a successful e-prescriber. The payment adjustment of 1.0% in 2012, 1.5% in 2013, and 2.0% in 2014 will result in an eligible professional or group practice participating in the e-prescribing Group Practice Reporting Option (eRx GPRO) receiving 99.0%, 98.5%, and 98.0% respectively of their Medicare Part B PFS amount for covered professional services.
Exclusion Criteria
The 2013 e-prescribing payment adjustment only applies to certain individual eligible professionals. CMS will automatically exclude those individual eligible professionals who meet the following criteria:
- The eligible professional was a successful e-prescriber during the 2011 e-prescribing 12- month reporting period (January 1, 2011 through December 31, 2011).
- The eligible professional is not an MD, DO, podiatrist, nurse practitioner, or physician assistant by June 30, 2012, based on primary taxonomy code in the National Plan and Provider Enumeration System (NPPES).
- The eligible professional did not have at least 100 Medicare Physician Fee Schedule (MPFS) cases containing an encounter code in the measure's denominator for dates of service from January 1, 2012 through June 30, 2012.
- The eligible professional did not have 10 percent or more of their MPFS allowable charges (per TIN) for encounter codes in the measure's denominator for dates of service from January 1, 2012 through June 30, 2012.
- The eligible professional does not have prescribing privileges and reported G8644 on a billable Medicare Part B service at least once on a claim between January 1, 2012 and June 30, 2012.
Avoiding the 2013 e-Prescribing Payment Adjustment
Individual eligible professionals and CMS-selected group practices participating in e-prescribing GPRO who were not successful e-prescribers in 2011 can avoid the 2013 e-prescribing payment adjustment by meeting the specified reporting requirements between January 1 and June 30, 2012.
January 1 - June 30, 2012 Reporting Requirements to Avoid the 2013 Payment Adjustment:
- Individual Eligible Professionals - 10 e-prescribing events via claims
- Small e-prescribing GPRO - 625 e-prescribing events via claims
- Large e-prescribing GPRO - 2,500 e-prescribing events via claims
CMS may exempt individual eligible professionals and group practices participating in e-prescribing GPRO from the 2013 e-prescribing payment adjustment if it is determined that compliance with the requirements for becoming a successful e-prescriber would result in a significant hardship.
Significant Hardships
The significant hardship categories are as follows:
- The eligible professional is unable to e-prescribe due to local, state, or federal law, or regulation
- The eligible professional has or will prescribe fewer than 100 prescriptions during a 6-month reporting period (January 1 through June 30, 2012)
- The eligible professional practices in a rural area without sufficient high-speed Internet access (G8642)
- The eligible professional practices in an area without sufficient available pharmacies for e-prescribing (G8643)
Submitting a Significant Hardship Code or Request
To request a significant hardship, individual eligible professionals and group practices participating in e-prescribing GPRO must submit their significant hardship exemption requests through the Quality Reporting Communication Support Page (Communication Support Page) on or between March 1 and June 30, 2012. Please remember that CMS will review these requests on a case-by-case basis. All decisions on significant hardship exemption requests will be final.
Significant hardships associated with a G-code may be submitted via the Communication Support Page or on at least one claim during the 2013 e-prescribing payment adjustment reporting period (January 1 through June 30, 2012). If submitting a significant hardship G-code via claims, it is not necessary to request the same hardship through the Communication Support Page.
If you have questions regarding the e-prescribing Incentive Program, e-prescribing payment adjustments, or need assistance submitting a hardship exemption request, please contact the QualityNet Help Desk at 866-288-8912 (TTY 877-715-6222) or via qnetsupport@sdps.org. They are available Monday through Friday from 7am to 7pm CST.
