Electronic Prescribing Incentive Program

The Centers for Medicare & Medicaid Services (CMS) has developed an incentive program for electronic prescribing, or e-prescribing. E-prescribing is defined as “the ability to electronically send an accurate, error-free and understandable prescription directly to a pharmacy from the point-of-care.” The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorized the 2009 E-prescribing incentive program, separate from the Physician Quality Reporting Initiative incentive reporting program.

The e-prescribing measure, formerly part of PQRI 2008 – measure #125, has been removed from the list of PQRI measures applicable for 2009. The goal of removing this measure from PQRI to create an incentive program based on e-prescribing is to advance the quality of care surrounding prescriptions/medications. The benefits involve four stakeholder groups: patients, payers, providers, and pharmacies.

Who is eligible to participate in this program?

In order to be eligible for this program, the following professionals must offer services listed in the CMS E-Prescribing Measure Specifications that represent at least 10 percent of their Medicare charges:

• Physicians
• Physical and occupations therapists
• Qualified speech-language pathologists
• Nurse practitioners
• Physician assistants
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Certified nurse midwives
• Clinical social workers
• Clinical psychologists
• Registered dietitians
• Nutrition professionals
• Qualified audiologists

CMS E-Prescribing Measure Specifications (25K PDF)

How does one begin participating in this program?

There is no registration required to participate in the e-prescribing program. Simply begin reporting the measure in 2009 with the Medicare claims process.

CMS 2009 E-Prescribing Made Simple (475K PDF)

CMS E-Prescribing Fact Sheet (170K PDF)

CMS Practical Guide to the E-Prescribing Incentive Program (340K PDF)

AMA Clinician’s Guide to E-Prescribing (1340K PDF)

CMS Sample E-Prescribing Claim Form (40K PDF)

What is the reporting period?

The e-prescribing reporting period runs for a full-year:
 January 1, 2009 – December 31, 2009.

What are the incentive amounts?

For each year, beginning in 2009, the incentive amounts for e-prescribing will change. Starting in 2012, there will be a penalty applied to those eligible who are NOT e-prescribing.

How can an eligible professional e-prescribe successfully to receive the incentive amount?

For the 2009 reporting period, an eligible professional must report, using a qualified e-prescribing system, one e-prescribing measure in at least 50% of the cases in which the measure is reportable.

What are the 2009 system requirements?

According to the CMS E-prescribing Measure Specifications, a qualified e-prescribing system is one that is capable of everything listed below:

1. Generating a complete active medication list incorporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs) if available:

2. Selecting medications, printing prescriptions, electronically transmitting prescriptions, and conducting all alerts;

3. Providing information related to the availability of lower cost, therapeutically appropriate alternatives (if any); and

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

What are the denominator codes?

• 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

What are the numerator codes?

• G8443: All prescriptions created during the encounter were generated using a qualified e-prescribing system.
• G8445: No prescriptions were generated during the encounter. Provider does have access to a qualified e-prescribing system.
• G8446: Provider does have access to a qualified e-prescribing system. Some or all prescriptions generated during the encounter were printed or phoned in as required by state or federal law or regulations, patient request, or pharmacy system being unable to receive electronic transmission; OR because they were for narcotics or other controlled substances.

Can an eligible professional report the e-prescribing measure for office visits as part of a global surgical package?

No, only separately payable office services count towards the 10% of Medicare payments that determines one’s eligibility.

Can an eligible professional sill report the e-prescribing measure in 2009 PQRI?

No, the e-prescribing measure has been removed from the list of 2009 PQRI measures.

Do controlled substances count as part of the e-prescribing incentive program?

No, the Drug Enforcement Agency (DEA) bans e-prescribing for controlled substances. However, the DEA has issued a proposed rule to permit e-prescribing for controlled substances under certain circumstances. Using G-code G8446, an eligible professional can report on the e-prescribing measure for controlled substances without using an e-prescribing system to do so.

Does an eligible professional have to report in PQRI in order to report in the E-Prescribing program?

No, reporting in PQRI is not required to participate in the e-prescribing incentive program.

Additional Resources:

CMS Web sites:

http://www.cms.hhs.gov/ERxIncentive/02_Spotlight.asp#TopOfPage 

http://www.cms.hhs.gov/EPrescribing/

AMA Web sites:

http://www.ama-assn.org/ama/pub/physician-resources/solutions-managing-your-practice/health-information-technology/hit-resources-activities/cms-electronic-prescribing.shtml

AMA E-Prescribing Learning Center

For more information, please contact Caitlin Burley, Quality Associate, American College of Surgeon: cburley@facs.org

Advocacy and Health Policy