Medicare Compliance & Reimbursement

E-prescribing is technically considered "optional," but if you are considered capable of participating and you choose not to do so in 2011, you could face payment penalties starting in 2012. That's the word from a Dec. 13 PQRI National Provider Call sponsored by CMS.

Between 2012 and 2014, the payment adjustment will kick in for practices that are not successful e-prescribers. Eligible professionals who don't e-prescribe in 2011 could collect one percent less than the Medicare Physician Fee Schedule amount in 2012, and that pay cut will go up to 1.5 percent in 2013 and two percent in 2014, said CMS' Daniel Green, MD, during the call.

CMS will analyze claims data from Jan. 1, 2011 through June 30, 2011 to determine whether you've submitted at least 10 e-prescriptions during the first six months of 2011. If not, you could be looking at the potential one percent payment cut in 2012.

"The reporting mechanism to avoid the payment adjustment is only valid through claims," Green said. If you're trying to earn an incentive, CMS will accept that through registries, but only claims submission will determine whether you're subject to the payment adjustment, he noted.

"Incentive payments for the 2009 electronic prescribing and PQRI payments have been issued to eligible professionals who met the criteria for successful and satisfactory reporting," Green said. Those payments went out between Sept. 21 and Oct. 22 for e-prescribing, and between Oct. 25 and Nov. 12 for PQRI, Green noted.

The incentive payments earned by individual participating physicians and other eligible professionals (EPs) were paid as a lump sum to the tax I.D. number associated with the EP's claim, Green said. "So if you're in a group with, let's say, five or six people, the payment, with any other folks who were successful in your group, was made as a lump sum to that tax I.D. number and it would be up to the practice to determine how to distribute that within the practice," he added. For more on CMS's e-prescribing program, visit www.cms.gov/ERxIncentive.