Get Ready for E-Prescribing

December 19, 2008

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The E-Prescribing Incentive Program went into effect on January 1, 2009, so start reporting now to qualify for the two percent bonus from Medicare. Please note this bonus is separate from the bonus for reporting quality measures under the Physician Quality Reporting Initiative (PQRI).

Change in Status for E-Prescribing

E-prescribing was a performance measure in the 2008 Physicians Quality Reporting Initiative (PQRI). Under the Medicare Improvements for Patients and Providers Act (MIPPA), authority was given to continue the PQRI program and separate out the e-prescribing measures. Following this decision, PQRI Measure #125 was no longer considered one of the PQRI measures and was raised to a separate status; this allowed for a temporary increase in the bonus along with relaxed requirements.

Thanks to this change, only 50 percent of eligible prescriptions must be transmitted electronically. Bonus payments will be available to successful e-prescribers from 2009 through 2013. A phased-in penalty for non-e-prescribing begins in 2012.

Year
Bonus
Penalty
2009 2.0% bonus
2010 2.0% bonus
2011 1.0% bonus
2012 1.0% bonus 1.0% penalty
2013 0.5% bonus 1.5% penalty
2014 and after 2.0% penalty

This rule states that eligible professionals must report they have e-prescribed if they have used a qualified program, and report this activity with one of the three appropriate G codes.

Requirements

A qualified prescribing program must have all four of the following functionalities:

  • Ability to generate a medication list
  • Medication selection, conducting safety checks (prompts that include drug information such as drug interactions, allergy concerns, and appropriate dose/route information)
  • Offering information on lower cost alternatives
  • Providing information on formulary or tiered medications, patient eligibility, and authorization requirements of the patient's drug plan

E-prescribing may be done from within a more comprehensive electronic medical record (EMR), or with a stand-alone program, as long as either can demonstrate the above features. As a practical matter, physicians can be confident that the e-prescribing system they use qualifies under this statute, as long as:

  1. The program has been certified by the Certification Commission for Healthcare Information Technology (CCHIT) within an EMR, since these e-prescribing functions are already established as part of the CCHIT Ambulatory EMR certification process
  2. The stand-alone program is recognized by the Surescripts network as having these functions

(Over ninety percent of electronic prescriptions are transmitted through Surescripts-RxHub. Alternative networks exist, but using one of these may run the risk of non-recognition. The Surescript website lists approved vendors.)

Rules for Software Compliance and Limitations

E-prescribing software is expected to be compliant with Medicare Part D Standards, which go into effect April 1, 2009. It should be emphasized that prescriptions must be transmitted in a true electronic format (called EDI, or electronic data interchange). This means that printed or faxed transmissions will not qualify as e-prescribing, even if they are the product of an EMR or prescribing program. Medicare will likely reluctantly recognize certain exceptions to this requirement in cases of network or electrical failures.

In order to qualify for the bonus, more than ten percent of your total allowable Medicare B charges must be within the specified outpatient CPT codes. In addition, the Secretary of HHS, at his discretion, may also require a threshold number of minimum prescriptions in order to qualify for the bonus.

Since this is a charge-based measure, appropriate G codes (serving as the denominator) must be submitted with the CPT I visit codes (numerator). So, if you have a qualified e-prescribing system (as defined above) use one of the scenarios below to choose the appropriate G code:

  • G8443—All prescriptions submitted via qualified e-prescribing system
  • G8445—E-prescribing system available, but no scripts written
  • G8446—E-prescribing system available, but statutes prohibit the prescription transmission or patient preference for paper
  • G8446—E-prescribing system available, but prescribed narcotics or other controlled substances
  • G8446—E-prescribing system available, but the pharmacy system can't receive electronic submissions

Find more information on the CMS website.