Gastroenterology Coding Alert

You could be penalized if you don't get your system up before June 30th.

If you do not have an electronic prescribing (ePrescribing or eScribing) system yet in place, or have not integrated one into your electronic medical record (EMR) system, you better get a move on it. You only have until June 30, 2011 to submit at least ten claims to Medicare to show that you are a successful eScriber for 2011. Otherwise, you are at risk of facing penalties assessed in 2012.

With limited time, it is smart to consider a stand-alone internet based system which you can implement relatively easy. You could get this system up and running right away, without depending on your electronic health record (EHR) to be up.

If you're still asking, "Can our practice afford not to adopt ePrescribing?" Then, the answer is NO. Today you need to start doing something.

Background: eScribing is part of Centers for Medicare and Medicaid Services' (CMS) incentive program called the Physician Quality Reporting System (PQRS). PQRS offers incentives to practices that meet CMS-set goals for the implementation and practice of electronic prescription on a regular basis. While CMS will pay you when you implement eScribing, it will penalize you when you don't put it into practice.

Since CMS published the first set of adopted standards, known as the foundation standards, in January 1, 2006, common misconceptions have clouded practices' awareness of eScribing. Get the inside scoop on what you should do and what you should know to turn your ePrescribing program into a success by finding out if the following claims are true or false.

Claim 1: CMS Requires a Fully Implemented EMR or EHR Before You Can Use and Benefit From eScribing

False: You have two types of systems to look at: (1) A system for e-prescribing only (a "stand-alone" system), or (2) An electronic health record (EHR) system with eScribing functionality, says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, N.J, in an audioconference she made for www.audioeducator.com on Feb. 16 entitled Incentives to Get on Board with e-Scribing in 2011 -- and Penalties if You Don't.

Important: Don't rush into buying your electronic health record and implementing it in time to avoid your eScribing penalties, warns Cobuzzi. You'll be wasting more money in both purchasing the wrong EHR and spending resources implementing the wrong EHR just to avoid penalties.

Claim 2: You Shouldn't Have A Hard Time Implementing eScribing

True: eScribing is technology light and relatively easy to implement within the office. In fact, you only have to meet four criteria in order for your eScribing system to qualify for the eScribing Incentive Program. CMS requires that it must:

1. Generate a complete medication list that incorporates data from pharmacies and benefit managers (if available);

2. Select medications, transmit prescriptions electronically using the applicable standards, and warn the prescriber of possible undesirable or unsafe situations;

3. Provide information on lower-cost, therapeuticallyappropriate alternatives (for 2009, tiered formulary information, if available, meets this requirement); and

4. Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient's drug plan.

In terms of reporting eScribing services, remember to bill it with an appropriate denominator code (e.g., 90801- 90809; 92002-92004; 99201-99205; 99211-99215). CMS guidelines state that 10 percent of your Part B Medicare charges, based on your Medicare fee, has to be represented by these denominator codes.

Caveat: If you're not a successful eScriber by June 30 and meet that 10 percent rule, you will be penalized. This means that in 2012, not only will you lose the one percent incentive, you will also get a one percent reduction. (In 2013, CMS will increase the penalty to a 1.5 percent payment reduction; in 2014 the reduction is two percent.)

In addition, eligible providers must report the eScribing G code G8553 (At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system) at least 25 times for Medicare visits, as well as the other listed services, for the calendar year.

Example: A patient goes to the gastroenterologist to treat her chronic heartburn. The gastroenterologist eprescribes pantoprazole, a generic acid suppression medicine. In this case, you would bill the office visit and G8553 to indicate that your physician completed the prescriptions electronically.

For a comprehensive review of CMS' eScribing incentive program, you may access Barbara Cobuzzi's webinar Incentives to Get on Board with e-Scribing in 2011 -- and Penalties if You Don't at http://www.audioeducator.com/incentives-to-geton-board-with-escribing-in-2011-and-penalties-if-you-don-t-544.html.