OSTEOPATHIC PHYSICIANS CONNECTING TO BETTER HEALTH CARE: EPRESCRIBING INCENTIVES FOR MEDICARE PART D

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OSTEOPATHIC PHYSICIANS CONNECTING TO BETTER
HEALTH CAREE-PRESCRIBING INCENTIVES FOR
MEDICARE PART DPAUL A. MARTIN DO, FACOFP, DIST.
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What is E-Prescribing (E-Rx)?

• Under Part D E-prescribing is the transmission
  of prescription or prescription related
  information between prescriber, dispenser,
  pharmacy benefit manager, or health plan, either
  directly or through an intermediary using
  electronic media
• Currently, e-prescribing is voluntary under Part
  D for prescribers and pharmacists
• Employs adopted Part D e-prescribing Foundation
  standards implemented January 1, 2006 through MMA

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What is E-Prescribing (E-Rx)?

• Does not require manual transcription at either
  end
• Traditional faxing is not electronic prescribing
• Secure E-mail is not electronic prescribing

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Benefits of E-prescribing

• Actively promotes appropriate drug usage
• Reduces medication errors
• Provides information about formulary-based drug
  coverage, including formulary alternatives and
  co-pay information
• Speeds up the process of renewing medications
• Renewal 25 seconds
• New just over a minute
• Provides instant connectivity between the health
  care provider, the pharmacy, health plans, PBMs,
  and other entities

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2008 PQRI E-Prescribing Measure

• Electronic Prescribing Structural Measure
  (measure 125) qualifies as one of three required
  measures in PQRI to earn an incentive payment
• Requirement for 2008 PQRI is to report the
  measure on 80 or more of eligible patients
• No separate incentive is available for successful
  E-prescribing in the 2008 PQRI

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Electronic Prescribing Measure in 2008 PQRI

• Currently, eligible professionals can report that
  they electronically prescribe (eRx) medications
  using a qualified e-prescribing program as
  defined in PQRI measure 125 under Adoption/Use
  of e-Prescribing by reporting one of the G-codes
  in the measure
• You must have and regularly use an electronic
  prescribing program to report the measure
• The electronic prescribing program must meet ALL
  of the requirements listed in PQRI measure 125
• If you have not adopted an electronic prescribing
  system that meets the specifications of the
  measure you cannot report on this measure
• The measure is intended to be reported on for
  EVERY patient visit in the denominator

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MIPPA Legislation - PQRI

• The Medicare Improvements for Patients and
  Providers Act (MIPPA), enacted July 15, 2008,
  contained several new authorities and
  requirements for quality reporting and PQRI for
  2009 and beyond
• Section 132 contains the new electronic
  prescribing incentive provisions

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MIPPA Legislation Successful Electronic
Prescriber, Section 132

• The legislation specifically refers to applicable
  electronic prescribing quality measures (i.e.
  e-prescribing measure 125 of PQRI 2008)
• The e-prescribing measure will be removed from
  2008 PQRI and added to the 2009 E-Prescribing
  incentive program
• The Secretary of HHS has the authority to update
  the specifications of the electronic prescribing
  measure in the future

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Incentives for Successful Electronic Prescribing
under MIPPA

• MIPPA provides a 2 payment incentive to
  eligible professionals who successfully prescribe
  (as defined by the statute) their medications
  electronically in 2009 and 2010 for 50 or more
  of their eligible ambulatory patients based on
  covered (allowed) Medicare Part B charges
• In 2011 and 2012 the payment incentive drops to
  1 of covered Medicare Part B charges
• In 2013 the incentive drops to 0.5 of the
  covered Medicare Part B charges

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G CODES

• Eligible Cases 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
• G8443 All prescriptions created during the
  encounter were generated using a qualified
  e-prescribing system
• G8445 No prescriptions were generated during the
  encounter. Eligible professional does have
  access to a qualified e-prescribing system
• G8446 Some or all prescriptions generated during
  the encounter were handwritten or phoned in due
  to required by state law, patient request, or
  qualified e-prescribing system being temporarily
  inoperable

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Future Penalties for NOT Electronically
Prescribing

• Eligible professionals who are not successfully
  using electronic prescribing by 2012 will be
  penalized 1 of their covered Medicare Part B
  charges.
• This means that these eligible professionals will
  be paid 99 for their covered Medicare Part B fee
  schedule services
• Fee reduction is prospective, eligible
  professionals will have to electronically
  prescribe by a date to be determined by the
  Secretary of HHS to be sure their fees are not
  reduced in 2012
• This date will not be before January 1, 2010
• Hardship exemption (i.e. rural professionals and
  pharmacies)

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Future Penalties for NOT Electronically
Prescribing

• In 2013 1.5 deducted from professionals
  covered Medicare Part B services
• Professionals will be paid at 98.5 of the
  physician fee schedule for covered services
• In 2014 and beyond penalty will increase to 2
• Professionals will receive 98 of the physician
  fee schedule for the covered traditional Medicare
  services they provide

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Qualified Electronic Prescribing Systems

• As a qualified e-prescribing system, the software
  program must be able to perform the following
  tasks
• Generate a medication list
• Select medications, transmit prescriptions
  electronically, and conduct safety checks
• Provide information on lower cost alternatives
• Provide information on formulary or tiered
  formulary medications, patient eligibility and
  authorization requirements received
  electronically from the patients drug plan
• Safety checks include automated prompts that
  offer information on the drug being prescribed,
  potential inappropriate dose or route of
  administration of the drug, drug-drug
  interactions, allergy concerns, and
  warnings/cautions

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Qualified eRx Systems for 2009

• To the extent possible, eRx systems for 2009
  should be compliant with the Medicare Part D
  prescribing standards which go into effect 4/1/09
• Vendors listed on the Surescripts website
  http//www.surescripts.com/get-connected.aspx?ptyp
  ephysician meet these 2009 Part D standards for
  the functions they provide.

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CCHIT

• Certification Commission for Healthcare
  Information Technology
• Currently certifies EHRs which contain eRx
  modules
• These systems meet the functionality requirements
  of the e-prescribing measure
• Some of the modules of a certified EHR may be
  available to be purchased separately
• CCHIT expects to review stand alone E-Prescribing
  software systems for certification starting in
  July 2009

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E-Prescribing of Controlled Substances

• April 1, 2008 - controlled substances no longer
  permitted to be e-prescribed after Final Rule for
  e-prescribing published
• DEA comment period on e-prescribing controlled
  substances closed on September 25, 2008
• Advocating for a technical solution to
  e-prescribing of controlled substances i.e.
• 2 factor authentication
• In-person proofing
• Two minute timeout
• AOA comments
• HHS will continue to work with DEA on integrating
  e-prescribing of controlled substances in a way
  that is
• Interoperable with existing e-prescribing systems
• Scaleable to work throughout the healthcare
  system without imposing an undue burden
• Promotes overall e-prescribing adoption

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Computer Generated Fax

• 2005 Foundation Standards regulation gave an
  exemption for entities using computer-generated
  fax technology
• Exemption tightened in last years (Nov. 2007)
  2008 Physician Fee Schedule (PFS) regulation to
  apply only to temporary transmission problems,
  effective 1/1/2009
• New information raised concerns about unintended
  consequences regarding refills
• In next years PFS to be published in Nov. 2008
  and effective for 2009, it is proposed to retain
  the exemption for prescription refill requests

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Where do we go from here?

• Look at lifting the long-term care exemption
• Determine the best approach with computer
  generated fax exemption
• Work with the DEA to develop a scaleable,
  interoperable, commercially viable solution to
  e-prescribing and controlled substances
• Continue to monitor the effective use of the
  current rules and standards of e-prescribing and
  modify as needed

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Additional Information

• CMS plans to have an eRx section on the PQRI
  website at www.cms.hhs.gov/pqri
• This section will contain information on
• MIPPA legislation
• A fact sheet describing the MIPPA E-Prescribing
  Incentive Provisions
• Part D Standards
• e-Prescribing Made Simple
• A list of vendors who have informed CMS that
  their software product complies with the new Part
  D standards as well as the functions described in
  the measure

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Implementation Schedule for 2009 e-Prescriber
Incentive

• The Physician Fee Schedule Final Rule will be
  published electronically by CMS in conjunction
  with any updates from the Secretary of HHS on or
  about 11/15/08.

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Thank YouQuestions?