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Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...

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19.02.2013 Views

CMS-1403-FC until December 31, 2008 for use in the 2009 E-Prescribing Incentive Program, we will not expand the basic scope of the denominator outside the professional office and outpatient setting. We believe that several reasons support the limitation of the 2009 e-prescribing measure (that is, Measure #125) denominator codes to physician and other eligible professional office and outpatient settings. First, physicians and other eligible professionals have limited ability to influence the adoption and availability of electronic prescribing systems in hospitals or other provider settings. Second, including codes for professional services in provider facility settings may negatively impact the ability of professionals who practice in office and facility settings to successfully report the electronic prescribing measure at the required 50 percent of cases. Without access to electronic prescribing for services furnished in a provider setting, the professional would be unable to report and these cases would count as not reporting if such codes were included in the measure denominator. Third, the effect of the electronic prescribing incentive payment is likely to have its greatest impact in stimulating adoption and use of electronic prescribing in the professional office and 686

CMS-1403-FC outpatient setting. While outpatient services are an imperfect marker, outpatient services are likely to represent the largest opportunity to expand electronic prescribing where prescribing is frequent and the decision to adopt electronic prescribing systems is also dependent on the choices, practices and funding by eligible professionals. Fourth, the statutory limitation that applies to eligibility for the incentive also applies to the future differential payment provisions. Extension of the denominator codes to hospital-based settings of care, may cause professionals who exclusively practice in such settings to be liable for a differential payment for services furnished in a setting where they have limited ability to influence the adoption of electronic prescribing. ii. Qualified Electronic Prescribing System – Required Functionalities and Part D E-Prescribing Standards To report Measure #125 the eligible professional must report one of three “G” codes, as will be discussed below, on the same claim for which one of the denominator codes is billed. In reporting any of the G codes, however, and thereby qualifying for the incentive payment for e-prescribing in 2009, the professional must have and regularly use a “qualified” electronic prescribing system 687

<strong>CMS</strong>-1403-FC<br />

until December 31, 2008 for use in the 2009 E-Prescribing<br />

Incentive Program, we will not expand the basic scope of<br />

the denominator outside the professional office and<br />

outpatient setting.<br />

We believe that several reasons support the limitation<br />

of the 2009 e-prescribing measure (that is, Measure #125)<br />

denominator codes to physician and other eligible<br />

professional office and outpatient settings. First,<br />

physicians and other eligible professionals have limited<br />

ability to influence the adoption and availability of<br />

electronic prescribing systems in hospitals or other<br />

provider settings. Second, including codes for<br />

professional services in provider facility settings may<br />

negatively impact the ability of professionals who practice<br />

in office and facility settings to successfully report the<br />

electronic prescribing measure at the required 50 percent<br />

of cases. Without access to electronic prescribing for<br />

services furnished in a provider setting, the professional<br />

would be unable to report and these cases would count as<br />

not reporting if such codes were included in the measure<br />

denominator. Third, the effect of the electronic<br />

prescribing incentive payment is likely to have its<br />

greatest impact in stimulating adoption and use of<br />

electronic prescribing in the professional office and<br />

686

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