South Florida Hospital News
Sunday May 26, 2019
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March 2009 - Volume 5 - Issue 9

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E-Prescribing: Are You Ready?

As most everyone is now aware, CMS started its e-prescribing initiative on January 1, 2009. Let me roll back the clock a bit and give you some background as to how CMS developed this particular initiative. The Physicianís Quality Reporting Initiative (PQRI) for 2008 included a measure #125 that allowed physicians to report on using an electronic prescribing module to do at least 50% of their Medicare prescriptions. This allowed physicians to collect a bonus equal to 2% of their Medicare Part B reimbursements. Beginning in 2009, CMS has removed this as part of the total PQRI reporting structure and created a new program that allows physicians to report, via G-codes, their compliance with the same 50% requirement as previously listed in PQRI measure #125.

To qualify for this particular initiative, the e-prescribing system used must meet certain requirements. These requirements are very specific as to the functionality that is necessary to make the system qualified. Some providers currently using an EMR may find it disconcerting to find out that their particular system may or may not have the required functionality. In addition, the regulations as to what constitutes a qualified system were not released until November 15, 2008. This allowed little time for EMR vendors or stand-alone e-prescribing vendors to analyze and create the needed functionality.

The requirement of obtaining a complete medication list from pharmacies and pharmacy benefit managers (PBMs) presents a complex and daunting task for system vendors. This requires the vendors either to connect to RxHub or to form alliances directly with the PBMs. The latter option is too expensive, very time consuming, and would require an extensive development and interface scheme that most EHR vendors will not be able to provide. This means that most vendors who were not already qualified are scrambling to get connected to RxHub, which is the only viable option for obtaining this data.

In my conversations with CMS, they have made it very clear that you must have a qualified system in place prior to reporting the G-codes associated with e-prescribing. Reporting e-prescribing G-codes before having a qualified system in place could lead to a Medicare audit as well as fines and/or sanctions.

To be qualified, a system must do the following:

1. Select medications, transmit prescriptions electronically using the applicable standards, and warn the prescriber of possible undesirable or unsafe situations.

Note: The prescription must be sent electronically. If the network converts the electronic prescription into a fax because the pharmacy isnít set up to receive electronic messages, this counts as e-prescribing. If the e-prescribing system is only capable of sending a fax directly from the e-prescribing system to the pharmacy, the system isnít a qualified e-prescribing system.

2. Provide information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patientís drug plan.

3. Provide information on lower-cost, therapeutically-appropriate alternatives. (For 2009, tiered formulary information, if available, meets this requirement.)

4. Generate a complete medication list that incorporates data from pharmacies and benefit managers (if available).

Here are the reporting G-codes that must apply to every Medicare part B patient seen:

You should report one of following G-codes (or numerator codes) on the claim you submit for each Medicare patient for each visit.

REPORT G8443 - If ALL of the prescriptions generated for this patient during this visit were sent via a qualified e-prescribing system.

REPORT G8445 - If NO prescriptions were generated for this patient during this visit.

REPORT G8446 - If SOME or ALL of the prescriptions generated for this patient during this visit were printed or phoned in as required by state or federal law or regulations, due to patient request, or due to the pharmacy system being unable to receive electronic transmission; OR because they were for narcotics or other controlled substances.

These measures must be reported on at least 50% of Medicare part B patients to qualify for the 2% reimbursement incentive.

Through the e-prescribing initiative, CMS could help lead physicians into the electronic world. It certainly enhances patient care by giving the physician a complete medication list, but does not negate the responsibility of the physician to determine the accuracy of that list. Overall, the initiative should lead to fewer medication errors and enhanced patient safety. Just make sure before you start that your system is qualified.

Dr. Jay Anders, MED3OOO Chief Medical Technology Officer, can be reached at Jay_AndersMD@MED3000.com or (412) 937-8887 ext. 329.
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