Avoid incentive double-dipping with new CMS information

August 11, 2011

Is your practice inadvertently trying to double-dip when it comes to Centers for Medicare & Medicaid Services (CMS) incentive programs? To make sure you don?t, the agency has posted new answers to frequently asked questions (FAQs) about how many incentives you can receive at once. The information is complicated but useful.

Is your practice inadvertently trying to double-dip when it comes to Centers for Medicare and Medicaid Services (CMS) incentive programs?

To make sure you don’t, the agency has posted new answers to frequently asked questions about how many incentives you can receive at once.

According to that information, if you receive an incentive under the Medicare Electronic Health Record (EHR) Incentive Program, you cannot receive an incentive payment under the eRx incentive program in the same program year, or vice versa. On the other hand, if you earn an incentive under the Medicaid EHR Incentive Program, you can receive an incentive payment under the eRx incentive program in the same program year.

CMS also sorted out whether physicians can participate in the 2011 Physician Quality Reporting System (formerly called PQRI), 2011 Electronic Prescribing (eRx) Incentive Program, and the EHR Incentive Program (also known as meaningful use) at the same time and earn incentives for each.

According to the FAQ, the Physician Quality Reporting System, eRx incentive program, and EHR incentive program are separate CMS programs, and the Physician Quality Reporting System incentive can be received in concert with participation in any other programs.

The three options for participation in the EHR incentive program-through Medicare, Medicare Advantage, or Medicaid-can complicate matters a bit. If you’re participating in the Medicare or Medicare Advantage options for the EHR incentive program, you still must report the eRx measure to avoid the penalty, but you are only eligible to receive one incentive payment. If you participate in both, you’ll get the EHR incentive payment.

You are required to report the eRx measure in 2011, even if your practice also participates in the Medicare or Medicare Advantage EHR incentive program, because claims data for the first 6 months of 2011 will be used to determine if you will face a 2012 eRx Payment Adjustment, according to CMS.

To be exempt also from the 2013 eRX payment adjustment, you need to generate successfully and report 25 electronic prescriptions, at least 10 of which are in the first 6 months of 2011, and submitted via claims to CMS.

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