MGMA urges HHS to harmonize e-Rx programs
The e-prescribing incentive payment program payment adjustment process must be modified to avoid unfairly penalizing eligible providers, according to the Medical Group Management Association (MGMA). In a March 16 letter to Health and Human Services Secretary Kathleen Sebelius, the 22,500-member association also urged the Centers for Medicare & Medicaid Services (CMS) to harmonize this process with the EHR incentive program.
Failure to do so will subject a significant number of e-prescribing eligible professionals (EPs) to payment adjustments in 2012 and 2013, according to the letter, which was signed by MGMA President and CEO William F. Jessee, MD, FACMPE.
The 2011 e-prescribing incentive program conflicts with the e-prescribing requirement in the EHR incentive program, the letter asserted, because EPs are required to report successful transmission on claims of a minimum of 10 prescriptions electronically within the first six months of 2011 to avoid a 2012 payment adjustment and must submit 25 e-prescriptions by the end of 2011 to avoid an adjustment in 2013. Under the EHR incentive program, however, an EP needs only to attest to meeting minimum e-prescribing thresholds for Stage 1.
“This makes it possible for an EP to earn incentives through the EHR incentive program but still be penalized through the e-prescribing program for submitting the same number of prescriptions,” the letter stated. “This lapse in coordination is not only problematic for EPs, it undermines the work CMS has done toward improving efficiency and promoting health IT.”
The association also is concerned about payment adjustments on specialty physicians who primarily provide drugs in their offices and not through prescriptions to a pharmacy. These specialists see a large percentage of Medicare patients and their income “will be significantly affected” if they fail to meet the e-prescribing requirements, according to the letter. In addition, a small number of physicians don’t routinely prescribe eligible prescriptions for Medicare patients during covered visits, and thus wouldn't prescribe in quantities sufficient to qualify for the bonus, but would still be subject to payment adjustment, the MGMA said.
To align e-prescribing and EHR incentives, the MGMA recommended that the federal agencies:
“The MGMA strongly supports the objectives of the e-prescribing and EHR incentive programs to stimulate adoption of health IT. Taking the actions we recommend will ensure that EPs are not unfairly penalized due to a lack of incentive program harmonization, insufficient hardship codes and a shortened reporting period,” the association concluded.
Failure to do so will subject a significant number of e-prescribing eligible professionals (EPs) to payment adjustments in 2012 and 2013, according to the letter, which was signed by MGMA President and CEO William F. Jessee, MD, FACMPE.
The 2011 e-prescribing incentive program conflicts with the e-prescribing requirement in the EHR incentive program, the letter asserted, because EPs are required to report successful transmission on claims of a minimum of 10 prescriptions electronically within the first six months of 2011 to avoid a 2012 payment adjustment and must submit 25 e-prescriptions by the end of 2011 to avoid an adjustment in 2013. Under the EHR incentive program, however, an EP needs only to attest to meeting minimum e-prescribing thresholds for Stage 1.
“This makes it possible for an EP to earn incentives through the EHR incentive program but still be penalized through the e-prescribing program for submitting the same number of prescriptions,” the letter stated. “This lapse in coordination is not only problematic for EPs, it undermines the work CMS has done toward improving efficiency and promoting health IT.”
The association also is concerned about payment adjustments on specialty physicians who primarily provide drugs in their offices and not through prescriptions to a pharmacy. These specialists see a large percentage of Medicare patients and their income “will be significantly affected” if they fail to meet the e-prescribing requirements, according to the letter. In addition, a small number of physicians don’t routinely prescribe eligible prescriptions for Medicare patients during covered visits, and thus wouldn't prescribe in quantities sufficient to qualify for the bonus, but would still be subject to payment adjustment, the MGMA said.
To align e-prescribing and EHR incentives, the MGMA recommended that the federal agencies:
- Recognize that EPs who have been attesting to meeting Stage 1 meaningful use criteria under the EHR incentive program during any 90-day window would not be subject to any e-prescribing payment adjustment in 2012 and 2013;
- Include additional exception categories so that more EPs and other healthcare professionals will be eligible for an exemption from the e-prescribing payment adjustment in 2012 and 2013; and
- Extend the 2011 e-prescribing reporting period to the first 10 months of 2011 for applicable Medicare office visits and services to avoid payment adjustment in 2012.
“The MGMA strongly supports the objectives of the e-prescribing and EHR incentive programs to stimulate adoption of health IT. Taking the actions we recommend will ensure that EPs are not unfairly penalized due to a lack of incentive program harmonization, insufficient hardship codes and a shortened reporting period,” the association concluded.