WASHINGTON – The Centers for Medicare and Medicaid Services is being asked to harmonize reporting for its EHR incentive program with its e-prescribing program so that physicians are not penalized “unfairly.”
The request comes from the Medical Group Management Association after a report released by the Government Accountability Office found duplicate requirements in the two programs.
The report states, “the two programs have established separate reporting requirements related to electronic prescribing, potentially requiring physicians – the largest and only group of providers eligible to earn incentive payments in both programs – to report to both from 2011-2014.”
The EHR program provides incentives from 2011 to 2016 and introduces penalties beginning in 2015, while the e-prescribing program provides incentives from 2009 to 2013 and provides for penalties from 2012 to 2014, when the program ends.
“Currently, the e-prescribing program requires EPs, or eligible providers, to report the successful transmission on claims of a minimum of 10 prescriptions electronically within the first six months of 2011 in order to avoid a 2012 payment adjustment,” wrote William F. Jessee, MD, president and CEO of the MGMA, in a March 15 letter to Health and Human Services Secretary Kathleen Sebelius.
“As you know, the EHR incentive program includes a requirement that an EP attest to meeting minimum e-prescribing thresholds for Stage 1 of the program. This makes it possible for an EP to earn incentives through the EHR incentive program but still be penalized through the e-prescribing program for submitting the same number of e-prescriptions. This lapse in coordination is not only problematic for EPs, it undermines the work CMS has done towards improving efficiency and promoting health information technology,” Jessee added.
One significant difference in the programs is that the EHR program requires providers to adopt and use EHR systems that are certified to meet criteria, which include electronic prescribing-related capabilities, while the e-prescribing program does not have a certification requirement.
“As a result, providers have no assurance that the systems they invest in will meet the electronic prescribing requirements,” said Linda Kohn, director of healthcare issues at the GAO.
“This inconsistency between the programs has the potential to create uncertainty among physicians” as to what technology is most appropriate for them to invest in, she said.
Last December the American Medical Association and 103 state and specialty medical societies asked the HHS for a revision in the Medicare e-prescribing penalty policy.
“This unreasonable policy leaves many physicians with little choice but to purchase and use a stand-alone e-prescribing program during the initial months of 2011 just to avoid penalties,” wrote AMA Board Secretary Steven J. Stack, MD. “HHS must take action now to align the e-prescribing and EHR incentive programs in order to alleviate confusion and reduce financial and administrative burdens on physician practices working to adopt health IT.”
According to the GAO report, “CMS recognizes that this duplication places additional burden on physicians, and we believe this duplication could affect the decision of physicians to adopt and use health information technology. However, CMS is still in the process of studying possible ways to address this duplication, and if the agency wants to eliminate the burden for providers in 2012, it would need to do so during its 2011 rulemaking.”
Mary Mosquera, Government Health IT, contributed to this story.
