Health Center Regulatory Issues, Uncategorized

Health Centers and Medicare Eprescribing

By: Susan Sumrell

We’ve been getting questions about FQHCs and the Medicare eprescribing payment adjustments, scheduled to begin in 2012. Section 132 of the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008 included a provision that would provide incentives for using eprescribing through 2011 and beginning in 2012, penalties for eligible providers who were not properly using eprescribing.

The law states that these incentives and payment adjustments are for those eligible providers that bill using the Medicare Physician Fee Schedule. Since Medicare FQHC services are reimbursed using an all inclusive per visit rate, instead of the Physician Fee Schedule, these services were not eligible for the eprescribing incentives, and will not be subject to the penalties. CMS notes this in the section on eligible providers on its eprescribing website here (see bolded section on FQHC services).

Eligible professionals do not need to participate in the Physician Quality Reporting System to participate in the Electronic Prescribing (eRx) Incentive Program.

Under the eRx Incentive Program, covered professional services are those paid under the Medicare Physician Fee Schedule (PFS). To the extent that eligible professionals are providing services which are paid under the PFS, those services are eligible for eRx Incentive Program.

Eligible and Able to Participate
The following professionals are eligible to participate in eRx Incentive Program: Eligible professionals must have prescribing authority in order to participate in this program.

1. Medicare physicians
• Doctor of Medicine
• Doctor of Osteopathy
• Doctor of Podiatric Medicine
• Doctor of Optometry
• Doctor of Oral Surgery
• Doctor of Dental Medicine
• Doctor of Chiropractic

2. Practitioner
• 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
• Audiologists

3. Therapists
• Physical Therapist
• Occupational Therapist
• Qualified Speech-Language Therapist

Eligible But Not Able to Participate
The following professionals are eligible to participate but are not able to participate for one or more reasons:

1. Professionals paid under or based upon the PFS billing Medicare Carriers/ Medicare Administrative Contractors (MACs) who do not bill directly.
2. Professionals paid under the PFS billing Medicare fiscal intermediaries (FIs) or MACs. The FI/MAC claims processing systems currently cannot accommodate billing at the individual physician or practitioner level:
• Critical access hospital (CAH), method II payment, where the physician or practitioner has reassigned his or her benefits to the CAH. In this situation, the CAH bills the regular FI for the professional services provided by the physician or practitioner.
• All institutional providers that bill for outpatient therapy provided by physical and occupational therapists and speech language pathologists (for example, hospital, skilled nursing facility Part B, home health agency, comprehensive outpatient rehabilitation facility, or outpatient rehabilitation facility). This does not apply to skilled nursing facilities under Part A.

Services payable under fee schedules or methodologies other than the PFS are not included in Physician Quality Reporting (for example, services provided in federally qualified health centers, independent diagnostic testing facilities, independent laboratories, hospitals [including method I critical access hospitals], rural health clinics, ambulance providers, and ambulatory surgery center facilities).

Eligible professionals participating in the eRx Incentive Program should familiarize themselves and their office staff with the eRx Incentive Program requirements for the relevant program year.

Please don’t hesitate to contact me if you have any questions on this or other Medicare related issues.