Feedback Report on E-Prescribing Incentive Program and Appeals Process
We also remain concerned that despite the AMA’s numerous requests, CMS has not yet produced 2009 e-prescribing data or issued 2009 incentive payments. Assessing the 2009 e-prescribing data is essential for evaluating the success of the incentive program and for applying lessons learned to the e-prescribing as well as other related programs like the Medicare and Medicaid EHR incentive programs. We urge CMS to provide feedback reports as soon as practicable so that physicians have timely, actionable information on potential problems in their e-prescribing reporting.
We also urge CMS to include a mechanism for physicians to appeal any aspect of the e-prescribing incentive program (e.g., payments or eligibility). We believe it is critical that physicians have an opportunity to appeal decisions that affect their ability to get incentives. Given the pitfalls experienced with the Medicare PQRI, we strongly recommend that a timely feedback loop and appeals process be built into the program to allow physicians to address reporting problems and appeal decisions that affect their eligibility to take part in the program or that affect their ability to get incentives.
Reporting of Successful E-Prescribers
In accordance with the law, CMS plans to publicly report the names of 2011 successful e-prescribers on the CMS website. We urge CMS to take appropriate measures to ensure the accuracy of the list of successful e-prescribers and to provide the appropriate disclaimers for the website listing. CMS should consider delaying the posting until CMS is able to pursue an educational campaign and is able to post appropriate disclaimers along with the list of successful e-prescribers. Physicians and patients should understand: the purpose for the posting given that this incentive program just started in 2009; that adjustments to the program have been made since 2009; and that the law does not allow physicians to participate in this program and others (e.g., Medicare EHR incentive program) simultaneously so many physicians have to select one incentive program over another. Please also refer to our comments on public reporting under the PQRI section.