The Carrots are Getting Smaller; The Sticks are Getting Bigger– February 27, 2013

Obtain Your Final eRx and PQRS Incentives, Avoid Penalties

Changes are imminent to two significant programs affecting Medicare Part B Fee-for-Service providers. The incentive portion of the Electronic Prescribing (eRx) Incentive Program winds down in 2013, meaning this is the last year for eligible individual providers and group practices to qualify for incentive payments for e-prescribing medications. Payment penalties will begin in 2014 for those not successfully e-prescribing to patients.

Also, 2014 is the last year to qualify for incentives from the Physician Quality Reporting System (PQRS) for eligible providers who report data on quality measures. Payment adjustments for those eligible and not reporting the data will begin in 2015 and continue indefinitely.

The following information can help providers obtain the last of the incentives and possibly avoid payment adjustments related to these programs — make sure you get all your carrots and avoid any sticks.

eRx Incentive Program
December 31, 2013, is the end of the reporting period for eligible providers to receive a .5% eRx incentive payment. Providers looking to receive their incentives must:

  • Generate eRx events and report the required number of denominator eligible visits
  • Report by claims, registry or qualified Electronic Health Records (EHR)
  • Ensure qualifying claims are processed by February 28, 2014

The six-month period of January 1, 2013, through June 30, 2013 is critical for providers who have never e-prescribed. To avoid a 2% payment adjustment in 2014, providers must:

  • Report by claims only
  • Ensure claims are processed by July 26, 2013

Or providers must satisfy one of the following requirements:

  • Have been a successful e-prescriber throughout the 12-month period of 2012
  • Be a successful e-prescriber for the first six months of 2013
  • Report a 2014 hardship
  • Achieve meaningful use of EHR for the 12-month period of 2012 or six-month period in 2013
  • Demonstrate intent to participate in the EHR Incentive Program by June 30, 2013

PQRS
The .5% PQRS incentive payment is still available for 2013 and 2014. Providers looking to receive their incentives must:

  • Be an eligible provider
  • Report by claims, registry or qualified EHR
  • Choose individual or group measure
  • If an individual provider, select at least three clinically applicable measures

Providers who do not achieve the PQRS incentive in 2013 may find themselves facing a 1.5% penalty in 2015, because payment adjustments under PQRS are applied two years after the reporting year. Accordingly, 2016 payment adjustments of 2% will be based off of reporting year 2014, and so on. Providers hoping to avoid PQRS 2015 payment adjustments must satisfy one of the following in 2013:

  • Meet criteria for satisfactory reporting for PQRS incentive
  • Report one valid measure or one measure group*
  • Elect to be analyzed under administrative claims based reporting

* Selection of a successful measure should involve an analysis of the most frequently treated disease burdens in your practice.

For assistance in complying with the eRx Incentive Program or PQRS, contact a member of the healthcare team. Additional information on the programs can also be found on the CMS website.

This communication is for information only, and any action should only be taken after a detailed review of the specific situation and appropriate consultation.

Notwithstanding that these materials do not constitute legal, accounting or other professional advice, as may be required by United States Treasury Regulations and IRS Circular 230, you should be advised that these materials are not intended or written to be used, and cannot be used by you or any other person, for the purpose of avoiding penalties that may be imposed under federal tax laws. No written statement contained in these materials may be used by any person to support the promotion or marketing of or to recommend any federal tax transaction(s) or matter(s) addressed in these materials, and any taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor with respect to any such federal tax transaction matter.