Penalties around EMR implementation beginning sooner than benefits?

Playing catch-up here since I was on vacation last weekend and missed my previous Wed post.

Stacey Marie Chapman had an interesting comment on a recent post by John Lynn over at emrandhipaa.com.  His post can be found here and her comment is below it.  Her comment included,

“I think one of the first signs will be visible come June of 2011, when the ePrescribing penalties begin. A payment adjustment (penalty) has been introduced for eligible professionals that have not implemented and employed a qualified eRx system by the end of the first 6 months of 2011. As penalties begin to pile, this may outweigh the providers’ ability to avoid the transformation.”

As a provider that uses an EMR, which had, in truth, been implemented with a rationale at least partially including the planned incentive payments from CMS (until July 1, we continue to see Medicare patients), I find this very interesting.  Medicare can begin imposing penalties long before any benefits can be received.  One cannot register their EMR system use with Medicare until at least after April 1, 2011, because right now their registration system blocks applicants from advancing beyond a specific screen for to get to “attestation”.

Since you must use the reporting system of Meaningful Use for at least 90 days to qualify for payments in 2011 (however little they may eventually be), there is question in my mind of how long into the future the date actually is going to be for being able to actually report for MU.  It’s a very much delayed process.  It leaves providers wondering when it will all come together.

Dr. West is an endocrinologist in private practice in Washington, DC. He completed fellowship training in Endocrinology and Metabolism at the Johns Hopkins University School of Medicine.  Dr. West opened The Washington Endocrine Clinic, PLLC, as a solo practice in 2009.   He can be reached at doctorwestindc@gmail.com.

About the author

Dr. Michael West

Dr. Michael West

Dr. West is an endocrinologist in private practice in Washington, DC. He completed fellowship training in Endocrinology and Metabolism at the Johns Hopkins University School of Medicine. Dr. West opened The Washington Endocrine Clinic, PLLC in 2009. He can be contacted at doctorwestindc@gmail.com.

2 Comments

  • Dr. West,

    Here is the actual content taken directly from CMS.

    “For purposes of determining which eligible professionals or group practices are subject to the payment adjustment in 2012, CMS will analyze claims data from January 1, 2011- June 30, 2011 to determine if the eligible professional has submitted at least 10 electronic prescriptions during the first six months of calendar year 2011”.

    You won’t actually be paying the penalties until 2012, though that’s hardly comforting.

    What this little known piece of information brings to mind is, that penalties actually start as of June 2011 if you’re not using an EMR. The focus, for most people, is that Medicare Incentive Payments decrease after 2012, with penalties beginning in 2015. But, for the most part, without an EMR how will one ePrescribe? (I won’t even bring up standalone ePrescribing)

    Which leads me to this: how many practices are aware of the eprescribing penalties? And, it actually changes the need to implement to an immediate process to avoid penalties. Even then, as you stated, “Medicare can begin imposing penalties long before any benefits can be received”.

    Moreover, also according to CMS: “Practices that successfully participate in the Medicare “Meaningful Use” EHR incentive program will not be eligible for the eRx incentive, but will still be eligible for imposition of the eRx payment adjustment.”

    Here is the link: http://www.cms.gov/ERxIncentive/Downloads/2011eRxIncentiveProgramUpdatefor2012PaymentAdjustment.pdf

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