Meditab Software Inc.

CMS proposes changes to Electronic Prescribing Incentive Program

May 27, 2011 – The Centers for Medicare and Medicaid Services (CMS) May 26 released a proposed rule that provides additional flexibility to physicians participating in the Electronic Prescribing (eRx) Incentive Program. Under the proposal, CMS would create four new hardship exemption categories that providers could claim to avoid the 2012 eRx payment adjustment penalty. Under the current program requirements, eligible professionals (EPs)or group practices that do not implement and use an e-prescribing system to complete at least 10 electronic orders before June 30, 2011, are subject to a 1 percent Medicare reimbursement penalty in 2012.

CMS acknowledged in the proposal that many stakeholders from the medical community expressed concern with the “administratively confusing, cumbersome, and unnecessarily duplicative” requirements under the eRx Incentive Program and the Medicare Electronic Health Record (EHR) Incentive Program.

The four specific hardship exemption categories proposed by CMS include:

  • “Eligible professionals who register to participate in the EHR Incentive Programs and adopt certified EHR technology;”
  • “Inability to electronically prescribe due to local, state, or federal law or regulation” (e.g., EPs who prescribe a large volume of narcotics, which may not be electronically prescribed in some states);
  • “Limited prescribing activity” (e.g., a Nurse Practitioner who does not write prescriptions under his or her own National Provider Identifier; or EPs with fewer than 10 prescriptions between Jan. 1, 2011 and June 30, 2011, but still meet the 10 percent threshold); and
  • “Insufficient opportunities to report the electronic prescribing measure due to limitations of the measure′s denominator;&rdquo (e.g., EP physicians such as surgeons that do not normally write prescriptions associated with any of the types of visits included in the eRx measure′s denominator).

The proposal also modifies the deadline for physicians who wish to submit hardship exemption requests to Oct. 1, 2011 (or 5 business days after the effective date of the final rule if later than Oct. 1). Comments on the proposal are due July 25, 2012.



Feedback