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CMS-1403-FC providers who do not adopt e-prescribing by the year 2012. The commenter also stated that structuring the elimination of the computer-generated facsimile exemption to coincide with this date would allow organizations the time needed to appropriately implement e-prescribing. Other commenters recommended that we adopt a computer- generated facsimile exemption for pharmacies in areas where prescribers who do not e-prescribe fall under the “significant hardship” exception contained in the MIPPA. Commenters also recommended that the computer-generated facsimile exemption be further modified so as to allow for use of the computer-generated facsimile exemption that was adopted in the November 7, 2005 final rule (the "original" computer-generated facsimile exemption) until 2014, when provider disincentives/penalties are maximized under the MIPPA, at which time a study could be conducted to determine the number of prescriptions being e-prescribed. We assume that the commenters’ intent would be to use the information gleaned from such a study as an indicator of whether or not e-prescribing had reached an acceptable level of adoption among providers and pharmacies, and that if an acceptable level of adoption among providers and pharmacies had been demonstrated, that the computer-generated facsimile exemption could be eliminated. 336
CMS-1403-FC Similarly, other commenters suggested that the exemption should be eliminated in 2012 when disincentives under the MIPAA e-prescribing incentive program go into effect, or in 2014, when e-prescribing provider disincentives/penalties are maximized under the MIPPA. Another commenter urged that we reinstate the original (from the November 7, 2005 final rule (70 FR 67568)) exemption for computer-generated facsimiles in its entirety, not just for prescription refill requests and transmission failures. Response: We agree with the commenters regarding the impact of the MIPPA. In general, the MIPPA provides payment incentives for eligible professionals who are “successful electronic prescribers” as that term is defined in the law. The incentive payments are 2 percent of the eligible professional’s allowed charges under the PFS for CY 2009 through CY 2010; 1.5 percent in CY 2011 through CY 2012, and a 0.5 percent in CY 2013. Conversely, the MIPPA calls for payment reductions, or disincentives, for those who are not successful electronic prescribers beginning in CY 2012. For CY 2012, the payment amount under the PFS will be reduced by 1 percent for eligible professionals who are not successful electronic prescribers. In subsequent years, the payment reduction is increased by 0.5 percent 337
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<strong>CMS</strong>-1403-FC<br />
providers who do not adopt e-prescribing by the year 2012.<br />
The commenter also stated that structuring the elimination<br />
of the computer-generated facsimile exemption to coincide<br />
with this date would allow organizations the time needed to<br />
appropriately implement e-prescribing.<br />
Other commenters recommended that we adopt a computer-<br />
generated facsimile exemption for pharmacies in areas where<br />
prescribers who do not e-prescribe fall under the<br />
“significant hardship” exception contained in the MIPPA.<br />
Commenters also recommended that the computer-generated<br />
facsimile exemption be further modified so as to allow for<br />
use of the computer-generated facsimile exemption that was<br />
adopted in the November 7, 2005 final rule (the "original"<br />
computer-generated facsimile exemption) until 2014, when<br />
provider disincentives/penalties are maximized under the<br />
MIPPA, at which time a study could be conducted to<br />
determine the number of prescriptions being e-prescribed.<br />
We assume that the commenters’ intent would be to use the<br />
information gleaned from such a study as an indicator of<br />
whether or not e-prescribing had reached an acceptable<br />
level of adoption among providers and pharmacies, and that<br />
if an acceptable level of adoption among providers and<br />
pharmacies had <strong>been</strong> demonstrated, that the<br />
computer-generated facsimile exemption could be eliminated.<br />
336