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Meaningful Health Care Informatics Blog

Mar 6 2011   3:46PM GMT

How to avoid penalties related to CMS electronic prescribing in 2012

Posted by: RedaChouffani
Compliance, e-prescribing, Electronic Perscribing, eRX, MIPPA

In January 2009, the Centers for Medicare and Medicaid Services (CMS) established an incentive for providers who use a qualified e-prescribing system to submit their Medicare patients’ prescription electronically. This program was of course authorized by The Medicare Improvements for Patients and Providers Act (MIPAA) and became the law of the land on July 15th, 2008.

Fast forward to 2011. With the deadline looming this summer, there are a growing number of physicians who recognize that the penalties associated with not participating in this program stand to negatively impact their bottom lines. In response to the upcoming reductions in reimbursements that will be doled out to non-participating providers, several organizations are gearing up for some last minute attempts to meet the deadline of June 2011 — which stands to reduce payments by 1% of total Medicare Reimbursements should it not be met.

Current Problem:

Organizations that have not participated in the e-prescribing program by June 30th of 2011 will face the following reduced payments:

1.           Reimbursement reductions of total Medicare Payments

                      i.      2012  — 1%

                     ii.      2013 — 1.50%

                    iii.      2014 — 2%

                    iv.      Subsequent years — 2%


2.             Meaningful use delays: While the Medicare incentive may not be as significant as meaningful use ones, organizations who are not participating in this program may still find themselves without a system that can electronically prescribe, which most likely mean that they are not currently using a certified EHR that is required for Meaningful use.



The 2012 e-prescribing penalty will NOT apply to:


             A professional who is not a physician, nurse practitioner, or physician assistant as of June 30, 2011;

             A physician for whom office visits and other services listed in the CMS e-Prescribing measure specifications represent less than 10 percent of their allowed Medicare charges in the first six months of 2011; or

             A physician who has less than 100 claims for patient services containing visit and service codes that fall within the e-Prescribing measure specifications for dates of service between Jan. 1, 2011 through June 30, 2011



The requirements to participate in the incentive program are very strain forward. There are three steps:


1.           Sign up qualified e-prescribing system: One of the simple ways to find out if your system has the ability to electronically prescribe is to visit Surescripts and identify if the product is listed in their certified products. If you are currently not using an EHR, you can select a stand-alone solution. You can find a list of available standalone packages here.

2.           Submit G-Code G8553 in your superbill or encounter so that it is submitted via CMS 1500 or X12 837 claim file to the CMS (90801-9; 90862; 92002; 92004; 92012; 92014; 96150-2; 99201-5; 99211-5; 99304-10; 99315-16; 99341-5; 99347-50; G0101; G0108-9).

3.           Ensure that you have at least 25 ambulatory visits and other applicable services for applicable CPT codes.






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