The June 30, 2013 deadline to participate in the Electronic Prescribing Incentive Program (“eRx”) and avoid the 2014 eRx payment adjustment is fast approaching.  Eligible Professionals (“EP’) looking to avoid the 2% payment adjustment in 2014 (payment adjustment means that EPs will only receive 98% of his/her Medicare Part B Physician Fee Schedule amount for covered professional services),  must either participate in the eRx program, fall under the exclusion criteria, or file for a hardship exemption by June 30, 2013.  Information regarding participation in the eRx program can be found here.

Exclusions

The following EPs will not be subject to the 2014 eRx payment adjustment if any one of the following applies:

1. EP successfully participates in the eRx program during the 2012 12-month reporting period (1/1/12 – 12/31/12).
2. EP is not an MD, DO, podiatrist, Nurse Practitioner or Physician Assistant.
3. EP does not have at least 100 Medicare Part B PFS cases containing the encounter code in the measure’s denominator between 1/1/2013-6/30/2013.
4. EP does not have 10% or more of their charges as Medicare Part B PFS allowable charges for encounter codes in the measure’s denominator during between 1/1/2013-6/30/2013.
5. EP does not have prescribing privileges and reported GT8644 on a payable Medicare Part B service on at least once on a claim between 1/1/2013-6/30/2013.
6. EP submits at least 10 eRx and reports the G-code G8553 between 1/1/2013-6/30/2013.
7. EP achieves Meaningful Use under the Medicare or Medicaid EHR Incentive Program during 2012 or between 1/1/2013-6/30/2013 (and attests before 6/30/2013).
8. EP demonstrates by registration of their intent to participate in the Medicare or Medicaid EHR Incentive Program during the 1/1/13-6/30/13 reporting period.
9. EP submits one hardship exemption G-code via any payable Medicare Part B PFS claim between 1/1/2013-6/30/2013.
10. EP request and CMS approves a hardship exemption.

Hardship Exemptions

EPs may be exempted from the payment adjustment if it is determined that compliance would result in a significant hardship.  Hardship exemptions must be submitted by June 30, 2013.  Such exemptions include:

1. EP’s inability to electronically prescribe due to state, federal or local law or regulation. (Submit using the Communication Support Page)
2. EP prescribes fewer than 100 prescriptions in a six month payment adjustment reporting period.  (Submit using the Communication Support Page)
3. EP practices in a rural area without sufficient high speed internet access .  (Submit using the Communication Support Page or use G8642 in at least one claim between 1/1/13-6/30/13)
4. EP practices in an area without sufficient available pharmacies for eRx.  (Submit using the Communication Support Page or use G8643 in at least one claim between 1/1/13-6/30/13)
5. EP achieves Meaningful Use under the Medicare or Medicaid EHR Incentive Program.
6. EP demonstrates their intent to participate in the Medicare or Medicaid EHR Incentive Program during the 1/1/13-6/30/13 reporting period.
7. EP does not have prescribing privileges between 1/1/2013-6/30/2013.  (File at least one claim with G8644 on a payable Medicare Part B service between 1/1/13-6/30/13)

Requesting a Hardship Exemption

To submit a hardship request, EPs must access the Communication Support Page located here (look at upper-left hand corner once on the site).  CMS suggests that when submitting a hardship, EPs should provide detailed justifications for the hardships.

Those hardships with G-codes may also be submitted by EPs on a claim with a payable Medicare Part B service during the six-month reporting period (1/1/13-6/30/13).

EPs that achieve Meaningful Use under the Medicare or Medicaid EHR Incentive Program or demonstrate their intent to participate in the Medicare or Medicaid EHR Incentive Program during the 1/1/13-6/30/13 reporting period will be determined by CMS through review of the EHR Incentive Program Attestation and Registration system.  CMS will automatically determine if these exemptions apply.

Group practices participating in 2013 eRx GPRO must indicate hardship exemptions during self-nominations/registration or submit an exemption request via the Communication Support Page (listed above).

For more information on eRx or other incentive programs please contact Elana Zana.