Electronic Prescribing

2011 Electronic Prescribing Incentive Program Requirements and 2012 and 2013 Electronic Prescribing Penalty Programs

In summary, CMS proposes to continue with the 2010 e-prescribing reporting requirement in 2011, which is to require eligible physicians to report on 25 services in 2011 involving electronic prescriptions in order to qualify for incentives. CMS also plans to publicly report the names of 2011 successful e-prescribers on CMS’ website.

In addition, CMS has provided and seeks input on the 2012 and 2013 penalty phases of the e-prescribing program. CMS’ proposal is to levy financial penalties in 2012 and 2013 against physicians who fail to report the e-prescribing measure during the first six months in 2011.

We strongly support CMS’ proposed requirements for the 2011 e-prescribing incentive payment program, which is to reduce the reporting burden from 50 percent of all applicable services, which was the requirement in 2009, to reporting only 25 services involving electronic prescriptions. We do however, strongly oppose CMS’ proposal to impose financial penalties in 2012 and 2013 against physicians based on their e-prescribing activity during the first six months of 2011. Instead, we strongly urge CMS to review 2012 and 2013 e-prescribing activity (not 2011 e-prescribing activity) in order to assess penalties in 2012 and 2013. We also strongly recommend that CMS add more exception categories so that physicians who face hardship are exempt from penalties in 2012 and 2013. Finally, we recommend feedback reports from CMS to assess the incentive program, the establishment of an appeals process, and that CMS ensure that the posting of the names of successful e-prescribers is done correctly.