Medicare
EHR Incentive Program Physician Quality Reporting System and Electronic
Prescribing Incentive Program Comparison
What incentive payments are
available to Medicare eligible professionals?
Provided a
Medicare Fee-For-Service (FFS) eligible professional (EP) meets the eligibility
and reporting requirements for each program, EPs may choose to participate in
three payment incentive programs:
A.
Physician Quality Reporting System: The 2006 Tax Relief and Health Care
Act (TRHCA) (P.L. 109-432) required the establishment of a physician quality
reporting system, including an incentive payment for EPs who satisfactorily
report data on quality measures for covered professional services furnished to
Medicare beneficiaries. CMS named this program the Physician Quality Reporting
SystemB. Electronic Prescribing (eRx) Incentive Program: Section 132 of
the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA)
authorized a new and separate incentive program for EPs who are successful
electronic prescribers as defined by MIPPA. This incentive program is separate
from and is in addition to the Physician Quality Reporting System program. EPs
do not need to participate in Physician Quality Reporting System to participate
in the eRx Incentive Program. Note: Medicare EPs may not earn incentives under
the eRx and Electronic Health Record incentive programs at the same time.
C. Electronic
Health Record (EHR) Incentive Program: The American Recovery and
Reinvestment Act of 2009 (Recovery Act) included the Health Information
Technology for Economic and Clinical Health Act, or the “HITECH Act,” which
established programs under Medicare and Medicaid to provide incentive payments
to EPs, hospitals, and critical access hospitals for the “meaningful use” of
certified EHR technology. Note: Medicare EPs may not earn incentives under the
eRx and Electronic Health Record incentive programs at the same time.
Who is
eligible to participate in each incentive program?
The
definition of an EP varies by incentive program and is defined as follows:
A.
Physician Quality Reporting System and eRx Programs define an EP as—
Physicians, defined as a doctor of medicine or osteopathy, a doctor of oral
surgery or dental medicine, a doctor of podiatric medicine, a doctor of
optometry, or a chiropractor;
Practitioners,
defined as a physician assistant, nurse practitioner, clinical nurse
specialist, certified registered nurse anesthetist (and anesthesiologist
assistant), certified nurse midwife, clinical social worker, clinical
psychologist, registered dietician, nutrition professional, or audiologist; and
Therapists,
defined as a physical therapist, occupational therapist, or qualified
speech-language therapist.
B. To
participate in the eRx Incentive Program, these professionals must additionally
have prescribing authority.
C.
Medicare EHR Incentive Program defines an EP as— A doctor of medicine or
osteopathy, a doctor of dental surgery or dental medicine, a doctor of
podiatric medicine, a doctor of optometry, or a chiropractor
D.
Medicaid EHR Incentive Program defines an EP as—Physicians, nurse
practitioners, certified nurse-midwives, dentists, and physician assistants who
practice in a Federally Qualified Health Center or rural health clinic that is
led by a physician assistant. • • •
What
are the time frames for each of the programs?
A.
The Physician Quality Reporting System incentive payments are available until
2014. Beginning in 2015, EPs who do not satisfactorily report Physician Quality
Reporting System measures will be subject to payment adjustments.
B.
The eRx incentive payments are available until 2013. Beginning in 2012 through
2014, payment adjustments will take effect for EPs who are not successful
e-prescribers. Payment adjustments under this program will end after 2014.
C. The EHR
Incentive Program began in calendar year 2011. EPs can earn incentive payments
for up to 5 years if they elect to receive their incentive payment through
Medicare or up to 6 years if they elect to receive their incentive payment
through Medicaid. However, no Medicare EHR incentive payments will be made to
EPs whose first year of participation in the Medicare EHR Program is 2015 or
later.
Beginning
in 2015, payment adjustments will take effect for Medicare FFS EPs who cannot
successfully demonstrate meaningful use of certified EHR technology. EPs can
begin to participate in the Medicaid EHR Incentive Program until 2016, and
there are no payment adjustments for not demonstrating meaningful use for
Medicaid EPs.
Paul
G. Silverio-Benet
Provider
Operations
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