August 23, 3010

A number of ABC pain medicine clients use e-prescribing technology and perform a sufficient number of evaluation and management (E/M) services to qualify, at least potentially, for Medicare’s eRx Incentive bonus.  This aspect of the practice of pain medicine has evolved a good deal in the last several years.  We suspect that the overall number of pain practices who are eligible for the eRx bonus is growing fast.  A review of the Medicare incentive payments and program requirements is in order.

Bonus amounts payable to “successful providers” as a percentage of the individual physician’s total allowed Medicare charges:

Penalties for prescribers that do not adopt e-prescribing, as a percentage decrease in the amount of total estimated allowed charges:

The 2.0% penalty will continue for each year starting with 2014 that the prescriber does not use eRx technology.

Successful provider: an “eligible provider” who uses a “qualified e-prescribing system” and who reports a sufficient number of E/M codes for visits during which an eRx was created.   E-prescribing may be reported together with any of the following CPT™ or HCPCS codes:

90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109

Minimum number of “eRx event” visits.  The successful provider will report at least 25 eRx event visits using one of the above codes plus code G8553 (“At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system.”)  In addition, the physician’s Medicare allowed charges for the E/M codes on the list must amount to 10% or more of his or her total annual estimated allowed charges.   

CMS recently reminded the provider community that it is not too late to start reporting eRx visits; physicians may still earn the incentive bonus if they meet the 25 eRx events/10% of total charges come from E/M codes on the list during the remaining four months of 2010.  There is no requirement that a provider declare his or her intention to participate in the eRx incentive program; simply reporting code G8553 on a claim for a visit will do the job. 

Two other reporting methods besides the standard claims-based method might make it easier for anesthesiologists/pain physicians who are only starting to e-prescribe now to qualify for the bonus:

• Registry-based reporting using a CMS-PQRI qualified registry. Eligible professionals have the option of using a qualified registry to assist in collecting eRx measure data and submitting 2010 data to CMS during the first quarter of 2011. The registry will submit this quality data directly to Medicare, eliminating the need for adding the QDC to the Medicare Part B claim. 
• EHR-based reporting, using a CMS-PQRI qualified EHR product, submitting 2010 data to CMS during the first quarter of 2011.

Both the registry and the EHR would have had to have been approved by CMS in time to be included on the list of registries/EHR vendors posted at .  These are the same vendors qualified for the PQRI program.  Even if there was no appropriate vendor for anesthesiology or pain practices in 2010, there may be one or more who qualify for 2011.  The Anesthesia Quality Institute may quite possibly qualify as a registry in the near future.

Eligible provider: In general, any medical professional with prescribing authority, including anesthesiologists and other physicians, and CRNAs and other advanced practice nurses where permitted by state scope of practice laws.

Qualified e-prescribing system:  to participate in the eRx incentive program,
prescribers must use a “qualified e-prescribing system.”  This may be either a standalone electronic system or it may be part of an integrated electronic health record (EHR).  A qualified system must be able to do all of the following:

1. Generate a complete active medication list (with information from prescription benefit managers or pharmacies if available);
    
2. Select medications, print prescriptions, transmit prescriptions electronically using the applicable standards, and warn the prescriber of possible undesirable or unsafe situations;
    
3. Provide information on lower-cost, therapeutically-appropriate alternatives (if any). The ability to receive tiered formulary information, if available, would suffice for this requirement for 2010 and 2011; and 
    
4. Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient’s drug plan (if available). 

Relationship between eRx Incentive Program, PQRI and EHR:  Physicians who participate and qualify as “meaningful users” for the Medicare Electronic Health Records Incentive Program for calendar year 2011 may not receive a separate, additional Medicare eRx Incentive Program payment.  Also, the eRx Incentive is separate from and is in addition to the physician quality reporting incentive (PQRI) program Eligible professionals do not need to participate in PQRI to participate in the Electronic Prescribing (eRx) Incentive Program.

Another eRx (and PQRI) area of interest to anesthesiologists and pain physicians is the changing standard for use of the group reporting option.  The proposed 2011 fee schedule rule would allow group reporting by groups numbering as few as two physicians.  We will publish information on this new option when it becomes final.  As always, we welcome your questions and comments.

With best wishes,

Tony Mira
President and CEO