Meaningful Use, ePrescribing, and PQRS: Need for Harmonization

While physicians are working feverishly to understand the complexities of meaningful use, their efforts are complicated by the demands of other government incentive programs that have similar goals but different rules. Two of the three cornerstones of ARRA are ePrescribing and reporting on quality measures, yet it is still necessary to comply separately with the regulations of EHR incentives (ARRA’s meaningful use), ePrescribing (MIPPA), and PQRS if physicians wish to maximize—or, in the near future, preserve—practice revenue.

EHR Incentive PaymentsThe chart to the right is taken from a 6-page CMS document that addresses the complicated interrelationships among EHR incentives, ePrescribing, and PQRS. For physicians, the challenge goes beyond understanding the potential payments; of greater significance is the administrative burden created by the discrepancies in reporting metrics and reporting periods among the three disparate programs. The following represent just a few of the inconsistencies inherent in the programs:

  • Under Medicare, physicians cannot receive both an EHR incentive and an ePrescribing (MIPPA) incentive in the same year. They can, however, receive both an EHR incentive and a PQRS incentive in the same year.
  • Future penalties for failure to demonstrate both meaningful use and PQRS will be additive. Whether cumulative penalties will apply for physicians who are not meaningful users and do not ePrescribe is not addressed in the CMS chart, but the prevailing understanding is that, instead, the harsher of the two penalties will prevail.
  • Because ePrescribing benchmarks differ, a physician could be deemed a successful ePrescriber under ARRA but not under MIPPA, and vice-versa.
  • Regardless of whether or not a physician receives incentives under ARRA, he/she must continue to comply with the MIPPA ePrescribing requirements (i.e., G-Coding) to avoid future MIPPA penalties. (Ironically, a physician could demonstrate meaningful use in 2011, receive an EHR incentive, but be penalized 1% under MIPPA in 2012 for failure to report G-Codes—a MIPPA, but not a meaningful use, requirement.)
  • Although many of the quality measures are common to both meaningful use and PQRS, separate reporting is required. Differences exist in the applicability of thresholds and in the reporting periods.

I am glad to see that the lack of program harmonization is being recognized—and I hope it will be successfully addressed in the next round of rule-making. Recently, the AMA distributed a survey “seeking physicians’ input on rules and regulations that increase their administrative costs and paperwork burden, or that interfere with patient care without a significant benefit to patients and/or the government.” Last week, the Government Accounting Office issued a recommendation to CMS that they eliminate overlapping ePrescribing requirements. Harmonizing the rules will go a long way toward encouraging widespread and successful participation in government programs that are aimed at increasing quality of patient care.

7 thoughts on “Meaningful Use, ePrescribing, and PQRS: Need for Harmonization

  1. Another example of bureaucratic nonsense that will accomplish little more than wasting physicians time emailing when it takes about 20 seconds to write, and hand over an Rx to a patient which he can take to any pharmacy whenever he wants.

  2. Great info.

    Do I have to worry that I will get a 1% e-Rx incentive and that will somehow electronically cause a block against me when I apply later in 2011 for my $28k EMR incentive… since both can not be taken in same year?


    [Evan Steele Says:]

    To Barry P MD,

    You do not have to worry about it. When you successfully demonstrate meaningful use in 2011, assuming that you have generated $24,000 in Medicare Part B revenue, CMS will send you a check for the $18,000 (not $28,000) EHR incentive. The 2011 ePrescribing incentive would not be determined until the end of February 2012, and at that point CMS will know that you already received an EHR incentive.

  3. I have 3 providers (2 MDs & 1 PA) in our practice. To meet the requirement of 10 e-Rx before 6/30/2011 do all 3 providers have to do 10 each or is it 10 for the practice?

    [Evan Steele says]
    Each provider must individually ePrescribe on 10 Medicare encounters by June 30 to avoid the 2012 penalties. PAs who are eligible for the program (see ePrescribing program requirements), bill under their own NPI number, and bill at least 100 Medicare encounters must also ePrescribe 10 times, unless they do not have prescribing privileges, in which case they must communicate this to CMS by putting the code G-8644 on one Medicare claim before June 30.

  4. If a physician waits to start Meaningful Use until next year (2012), will they be required to report for the full 12 months, regardless if they do PQRS this year (2011)?

    [Evan Steele says:]
    The provider’s first payment year requires only a 90-day reporting period, regardless of calendar year. PQRS is a separate program, and participation in PQRS has no bearing on the EHR Incentives.

  5. If the organization that I work for is filing for, and receiving all the benefit from this program in my name is it true that I can not do so myself independently later? Is there some precedent set regarding this? It sounds like fraud, taking someone else’s grant because they work for you…

  6. Are Residents able to participate in the Meaningful Use initiative if they have an NPI number? I’m not able to locate these qualifications specifically.

    [From Evan Steele:]

    Yes, residents are eligible, assuming that they are not hospital-based physicians (as defined by the legislation) and that they generate Part B allowed charges under their own NPI number. If they bill $24,000, they can earn the maximum incentive of $18,000; if they bill less, their incentive will be 75% of their Medicare charges.

    As stated on CMS’ FAQ website, “For the Medicare EHR Incentive Program, a resident must meet the definition of a Medicare eligible professional, be in the Provider Enrollment and Chain Ownership System (PECOS), with an enrollment status of APPROVED and have Part B allowed charges to be eligible for the Medicare EHR incentives.”

  7. Question- How many patients (per provider) do we have to use eprescribe for Medicare patients that are physically in the office?

    [From Evan Steele:]
    If a provider wishes to earn an ePrescribing incentive in 2012, assuming he/she is not pursuing the EHR Incentives this year, he must ePrescribe on 25 Medicare encounters with the specified CPT codes during 2012. (These codes are listed on our website:

    To avoid the 2013 ePrescribing penalty, (if he has not already done so), he must ePrescribe 10 times between January and June, 2012 on any types of Medicare visits. To avoid the 2014 ePrescribing penalty, he can either ePrescribe 25 times on Medicare visits with the above CPT codes between January and December, 2012 or 10 times on any Medicare visits between January and June 2013.

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