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American Association of Oral and Maxillofacial Surgeons

Practice Management & Allied Staff News & Materials

E-Prescribing Incentive and Penalty Reminder

June 17th, 2011

As a reminder, oral and maxillofacial surgeons are eligible for the Medicare E-Prescribing Incentive that became effective under the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA). To be eligible, 10% of an OMS' Part B charges must be comprised of codes considered to be a "denominator" of performance measure G8553 (at least one e-prescription generated and transmitted electronically using a qualified e-prescribing system). Denominators include Evaluation and Management codes that are not part of a global surgical package.

In order to successfully e-prescribe (eRX) and earn the incentive, an OMS must generate and report via a "qualified e-prescribing system" one or more e-prescriptions associated with a patient visit with a minimum of 25 unique visits per year. However, in order to avoid the 2012 eRx payment adjustment of -1%, an eligible OMS must report on a minimum of 10 unique visits via claims from January 1, 2011 through June 30, 2011. Each visit must be accompanied by the eRx G-code attesting that during the patient visit at least one prescription was electronically prescribed.

CMS has established three hardship exemption codes for eligible providers to report in order to avoid the payment adjustment.

G8642-practices in a rural area without sufficient high speed internet access;

G8643-practices in an area without sufficient available pharmacies for e-prescribing;

G8644- does not have prescribing privileges.

CMS released a proposed rule on May 26, 2011 that may extend the reporting period to October 1, 2011 which will allow eligible OMS more time to submit the minimum of 10 visits as well as more hardship exemption options to avoid the payment penalty in 2012. Proposed exemptions include:

  • Plan to participate in the Electronic Health Records (EHR) Incentive program in 2011 but delayed buying an e-Rx system.
  • Providers cannot e-prescribe due to state or federal law restrictions.
  • An eligible professional who does not prescribe often.
  • Physicians who prescribe frequently but only for ineligible types of visits, such as surgical procedures.

Until this proposed rule is final, eligible providers will have to submit e-RXs for a minimum of 10 patient visits by June 30th in order to avoid the payment penalty. You may visit the AAOMS website for additional information on the E-Prescribing Incentive Program or the CMS website for complete details on the incentive program including a list of reportable denominators.