Otolaryngology Coding Alert

Get your system moving before June 30^th or you'll pay the price.

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 demonstrating that you are a successful eScriber for 2011. Otherwise, you are at risk of not only losing the bonus in 2011 but according to the rulemaking for 2011, also facing penalties assessed, reducing your Medicare fee schedule by 1 percent 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, at a low cost, with simplified a implementation timeline and without depending on your electronic health record (EHR) selection and implementation which is both much more extensive, costly and more complicated to implement.

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. The system was designed with "a carrot and a stick". While we have been enjoying the "carrot" for the past few years, the "stick is on the cusp of being implemented as of June 30^th per the 2011 Rulemaking. CMS will pay you when you implement eScribing in 2011 (a 1 percent bonus), it will penalize you when you don't put it into practice, a 1 percent penalty in 2012 if 10 claims are not demonstrated as successfully ePrescribed by June 30^th, 2011 and a 1.5 percent penalty in 2013 if a total of 25 claims are not demonstrated as successfully ePrescribed for 2011.

Physicians, Physical or occupational therapists, speech-language pathologists, nurse practitioners, physician assistants, and clinical nurse specialist are just some of the professionals eligible to do eScribing. Remember the general rule of eligibility: If you can't write a prescription in your state, you are not qualified to do eScribing.

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 of false.

Claim 1: Faxing Prescription To A Pharmacy Will Fulfill The Requirements Of eScribing

False: You have to send the prescription electronically, not by fax. Some network that sends the electronic prescription to a pharmacy would convert it into a fax because the pharmacy doesn't have the capability to get an electronic prescription. In this case, the process still counts as eScribing.

On the other hand, if your eScribing system is only capable of sending a fax directly to the pharmacy, the system isn't qualified as an eScribing system. You can find CMS' detailed system requirements on eScribing at the Measures Specifications information online (Measure #125), www.cms.gov/ERxIncentive.

Claim 2: CMS Requires A Fully Implemented EMR or EHR Before You Can Use and Benefit From eScribing

False: You have two types of system 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. This table should help you decide between the two:

Important: Don't rush in buying your electronic health record and implementing it when you are not ready, just to get it up in time to avoid your eScribing penalties, warns Cobuzzi. You're going to be wasting more money in both purchasing the wrong EHR and spending resources implementing the wrong EHR just to avoid penalties.

"You want to make sure that you select the right EHR for you: You research to select the proper EHR which takes a great deal of time and investigation, then you order the correct system; you get ready for the implementation; and you do a good staged implementation of the system for a successful EHR that will be used correctly in the practice. That takes time -- sometimes up to a year for selection, training, and implementation," she adds.

You can choose from a number of stand-alone eScribing systems that are independent of EMR or EHR. The free system available over the internet is called National ePrescribing Patient Safety Initiative (NEPSI) (www.nationalerx.com). While it is simple, safe, secure, and free, you will not get any human support for assistance and training -- you have to figure it all out by yourself and use on line help files. Other stand-alone certified eScribing systems include Dr First (www.drfirst.com) and RxNT (www.rxnt.com). Go to the SureScripts website and make sure you select an online eScribing system that is a certified system. SureScripts, which is one of the clearing houses for eScribing, has a listing of the standalone systems and lists the status of their certification. Only use of a certified system will satisfy Medicare's requirement and allow the use of the G8553 which means that at least one ePrescription was generated at the encounter. The site is: www.surescripts.net/certification-status.html.

Claim 3: 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 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, therapeutically-appropriate 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 a denominator code which include 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, G0101, G0108, G0109, 99304; 99305; 99306; 99307; 99308; 99309; 99310; 99315; 99316; 99341; 99342; 99343; 99344; 99345; 99347; 99348; 99349; 99350; and 90862. 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.

Otolaryngology application: "Basically we're doing 99201 through 99215; you may be doing some nursing home (99304 through 99316)," says Cobuzzi. "You have to take your total Medicare charges (based on the Medicare fee schedule) for the year, take the charges for these codes, and make sure these codes represent 10 percent of your total charges." If not, the ePrescription rules do not apply to you and you do not have to be concerned about either the "carrot or stick" since you do not meet the 10 percent rule.

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 1.5 percent; in 2014 the penalty is increased to 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. Say your physician has $100,000 in established Part B Medicare charges. If $15,000 of that $100,000 is based on those denominator codes, then she is qualified for the eScribing bonus/penalty. If only $5,000 is based on those denominator codes, then she is not qualified for the incentive/penalty.

As the rules sit currently, a practice can actually receive the bonus in 2011 and still get penalized in 2012. If they do not report G8553 at least 10 times by June 30^th, they will be penalized in 2012, but if they then report G8553 at least 25 times between July 1^st and the end of 2011, they will receive the bonus for 2011. There are organizations such as MGMA that have submitted white papers requesting the penalty structure for 2012 be changed, and that ePrescribing bonuses and penalties be aligned, with EHR bonuses and penalties.

Example: A patient goes to the otolaryngologist to treat her sinus infection. The otolaryngologist eprescribes an antibiotic and a steroid nasal spray. She also tells the patient to get Claritin and Ocean drops over the counter. In this case, you would bill the office visit and G8553 to indicate that your physician completed the prescriptions electronically for the antibiotic (except Claritin and Ocean drops).

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-get-on-board-with-escribing-in-2011-and-penalties-if-you-don-t-544.html.