E-prescribing pay cuts loom for some in 2014, 2015

Some practices may find 2014 immediately off to the wrong foot when their Medicare payments are reduced by 2 percent for failing to participate successfully in Medicare’s E-prescribing Incentive Program. Unfortunately, at this point successfully claiming an exemption may be the only way to stave off the cut for non-reporters, unless you are prepared to report data via a Registry in the first quarter of 2014 or you plan to transmit the information via EHR.

The news is better for 2015 – to avoid a 2 percent pay cut that year, you can still transmit 25 unique electronic prescriptions with one of the denominator codes below by including G8853 on the claim.

The e-Rx Incentive Program has been around since 2009, providing extra payments to those who successfully e-prescribe according to CMS policy. But that carrot, meant to encourage reluctant providers to embrace e-prescribing, was always meant to become a stick for those who stayed away. 

2014 is that time. No incentive payment is available to be added to 2014 payments for those who successfully e-prescribed. 

CMS will, however, assess a 2 percent penalty to physicians, podiatrists, PAs and NPs when the following circumstances apply:

•  10 percent of the provider’s eligible charges between Jan. 1-June 30, 2013, consisted of services eligible for e-prescribing.

• The provider had at least 100 Part B encounters eligible for e-prescribing between Jan. 1-June 30, 2013.
  
  Eligible claims are those where the following services are billed: 90791, 90792, 90832, 90834, 90837, 90839, 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, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109.
  
  Here are circumstances where CMS will not apply the 2014 penalty:
  * The provider reports G8553 to signify submitted at least 10 e-prescriptions for any service between Jan. 1-June 30, 2013.
  * The provider achieves EHR Meaningful Use in either 2012 or the first half of 2013.
  * The provider doesn’t have prescribing privileges and reports G8644 at least once in the first half of 2013.
  * The provider shows intent to achieve EHR meaningful use in the first half of 2013 by registering and providing an EHR certification ID.
  * The provider is able to demonstrate a hardship that prevents e-prescribing, among them living in an area with limited access to high-speed Internet (reported as G8642); lives in an area without enough pharmacies for e-prescribing (G8643).
  
  The same rules apply to those practices who registered for the Group Practice Reporting Option by Jan. 31, 2013, but in that instance an informal review may be requested by the group practice if CMS applies a payment penalty.