JUNE, 2009: Existing Government Incentive Programs to Adopt EHR’s
Federal and State governments have had a variety of incentive programs, such as e-prescribing, in place prior to the passing of the Stimulus Package for the use of Health Information Technology.
Summary of National Incentives already in place:
- 46 programs offered by government agencies, insurance plans, employer coalitions and public-private partnerships
- 59 programs, representing 159 hospitals, in response to federal “safe harbor” regulations on health IT donations
- 52,474 physicians (and other clinicians) receiving or offered financial assistance in purchasing EHR capabilities
- $783.45 million in known dollar value of these incentive programs
- 21 state governments enacting some form of EHR adoption program
- Incentive programs specific to New York
- Health Care Efficiency and Affordability Law for New Yorkers (HEAL NY)
- Primary Care Information Project (PCIP),
- Capital District Physicians’ Health Plan, Albany, NY, (a network of 7,500 physicians and 75 hospitals in 29 counties of New York and 7 counties in Vermont) announced in January 2008 a program to provide more than $1 million to assist physicians in small practices with implementing EHRs; 25 practices applied for the funding.
- Programs taking advantage of Stark exception, anti-kickback safe harbor in NY:
- Arnot Ogden Medical Center, Elmira, NY
- Continuum Health Partners, New York, NY (5 hospitals)
E-prescribing: E-prescriptions are computer-generated prescriptions created by a healthcare provider and sent electronically to the pharmacy. The provider enters the prescription directly into a computer or handheld device at the point-of-care. These e-prescription systems can be stand alone or part of an EHR. The privacy of personal health information contained in the prescriptions is protected by the Health Insurance Portability and Accountability Act (HIPAA). E-prescribing is a key element to the government’s plan to expedite the adoption of electronic medical records and to build a national electronic health information infrastructure in the United States.
In 2008, Medicare authorized a new program for eligible professionals who are successful electronic prescribers (e-Prescribers) for 2009 through 2013. For 2009 and 2010, the Secretary is authorized to provide successful electronic prescribers an incentive payment equal to 2.0% of the total estimated allowed charges submitted not later than 2 months after the end of the reporting period (January 1, 2009 – December 31, 2009).
Eligible Professionals (EPs): The following professionals, who have prescribing authority, are eligible to participate in E-Prescribing Incentive Program. If they successfully report the e-prescribing measure in 2009 they may be eligible to receive an incentive payment equal to 2% of all of their Medicare Part B (FFS) allowed charges for services furnished during the reporting period (January 1 through December 31).
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To e-prescribe:
- You must have an e-prescribing system/program and are routinely using it.
- The system must be able to do the following to be a qualified system:
- Generates a complete active medication list using electronic data received from applicable pharmacies and pharmacy benefit managers (PBM), if available.
- Allows eligible professionals to select medications, print prescriptions, transmit prescriptions electronically and conducts all alerts. Alerts include automated prompts that offer information on the drug being prescribed and warn the prescriber of possible undesirable or unsafe situations such as potentially inappropriate dose or route of administration of the drug, drug-drug interactions, allergy concerns, or warnings/cautions.
- Provides information on lower cost therapeutically appropriate alternatives, if any. For 2009, a system that can receive tiered formulary information, if available, from the PBM would satisfy this requirement.
- Provides information on formulary or tiered formulary medications, patient eligibility and authorization requirements received electronically from the patient’s drug plan (if available).
- In addition to the system functionalities mentioned above, the system or program should meet the Part D specifications for messaging that will be implemented on April 1, 2009.
- For the 2009 e-prescribing reporting year, to be a successful e-prescriber and qualify to receive an incentive payment at least 10% of the eligible professional's total Medicare Part B allowed charges for 2009 are from covered services listed in the denominator of the measure. Of those eligible cases 50% of them must be reported.
- The following CPT or HCPCS G-codes are included in the denominator of the e-prescribing measure:
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, G0101, G0108, G0109 - Reporting:
If you billed one of the CPT or HCPCS G-codes above then report one of the following G-codes (or numerator codes) on the claim you submit for this Medicare patient for the visit.
- If ALL of the prescriptions generated for this patient during this visit were sent via a qualified e-prescribing system: REPORT G8443
- If NO prescriptions were generated for this patient during this visit: REPORT G8445
- If SOME or ALL of the prescriptions generated for this patient during this visit were printed or phoned in as required by state or federal law or regulations, due to patient request, or due to the pharmacy system being unable to receive electronic transmission; OR because they were for narcotics or other controlled substances: REPORT G8446
- There is NO NEED to register to participate in this incentive program. Simply begin submitting the appropriate G-codes on your claims if you satisfy the above requirements.
e-Prescribing penalties:
- Beginning in 2012, providers not reporting successful e-prescribing to Medicare will be penalized
- Penalties will also be based upon total allowed Part B charges billed by providers per annual reporting period
- Provider's Medicare payments will be reduced according to the following schedule:
- 1.0% for 2012
- 1.5% for 2013
- 2.0% for 2014 and each subsequent year
KEY POINTS:
- There are existing incentive programs in place to encourage the adoption of EHRs such as e-prescribing, PQRI, and Safe Harbors.
- E-Prescribing: Providers can receive up to 2% from Medicare up to 2013. Starting in 2012 there will be a penalty for not prescribing electronically.
KEY ISSUES TO THINK ABOUT:
- Do I e-prescribe in a standalone system, as part of an EHR, or as part of a Health Information Exchage.
- How does e-prescribing fit into the stimulus package?
LOOK TO eINFO@PRI TO STAY UP-TO-DATE AS THESE AND OTHER QUESTIONS ARE ANSWERED