Q: What bonus programs exist to provide extra revenue from the Centers for Medicare and Medicaid Services?
A: There are currently a variety of bonus programs that exist for eye-care professionals. They include: the Health Professional Shortage Area (HPSA); Physician Quality Reporting Initiative; E-Prescribing; and Health Information Technology.
The HPSA bonus is based on the practice's geographic location. Bonus payments are made quarterly and typically do not require any action by providers. The remaining three bonus programs require providers to submit information to qualify for bonus dollars.
Q: Are physicians participating in the PQRI, E-Rx and HIT receiving bonus payments?
A: To date, the PQRI program is the only program that has released bonus payments. In 2008 and 2009, CMS paid bonuses to approximately 54 to 55 percent of participants for the 2007 and 2008 programs. The E-Rx program began in 2009 and payments to successful participants are expected in the fall of 2010. The HIT bonus program begins in 2011.
Q: Is enrollment into these programs voluntary or mandatory?
A: These programs will all become mandatory in the coming years. Non-participation will result in a reduction to your Medicare fee schedule. The Patient Protection and Affordable Care Act makes PQRI enrollment mandatory by 2015 with an anticipated reduction to Medicare reimbursement of 1.5 percent in 2015 and 2 percent in 2016 and beyond.
The E-Rx program, authorized by the Medicare Improvements for Patients and Providers Act of 2008, requires participation by 2012. The proposed penalty for nonparticipation is a 1-percent reduction in Medicare payments in 2012 and a 1.5-percent reduction in 2013.
Although still a work in progress, the HIT bonus requires participation by 2015 or additional Medicare reimbursement reductions will apply.
Q: Do any of these programs have exemptions for participating physicians?
A: A proposed exemption does exist for the E-Rx program. A "G" code in support of a hardship exemption for 2012 may be submitted if the practice is in a rural area with a limited high-speed Internet connection, or the practice is in an area with limited pharmacies available to accept electronic prescriptions.
The exemption for HIT has not yet been defined. No exemption exists for PQRI participation.
Q: Are the bonuses scheduled to increase or decrease in the future?
A: Decrease. The PQRI bonus is slated to be 1 percent in 2011 and then 0.5 percent through 2014. No PQRI bonus payments are planned after 2014. The E-Rx bonus payment decreases to 1 percent in 2011 and 2012 and 0.5 percent in 2013. The HIT bonus is not a percentage and relies on meeting specific criteria each year from 2011 through 2016.
Q: What changes can we expect to see with PQRI and E-Rx in 2011?
A: Final changes will be published in the Medicare Physician Fee Schedule in November. Proposed changes include:
- Continuation of two reporting periods (12 months, January through December; or six months, July through December);
- Threshold reduced to 50 percent from 80 percent for each of three measures for successful re-porting when submitting on individual claims;
- Maintaining the 80 percent threshold requirement for at least three measures when using a qualified registry or electronic health record reporting;
- Retirement of measure #139: Cataracts: Comprehensive Preoperative Assessment for Cataract Surgery with Intraocular Lens Placement;
- Website posting of successful physicians and groups reporting measures in 2011.
The final changes to E-Rx will also be published in the Medicare Physician Fee Schedule.
As previously published, the E-Rx bonus payment will not be available to any participants that are also receiving the HIT bonus in 2011. Other changes to the program include:
- Maintaining the annual reporting period only;
- Continuing 25 E-Rx events to determine successful participation;
- Retaining the requirement that 10 percent of eligible charges be based on codes in the denominator (visits codes, not surgical or testing codes).
Q: Is it too late to join the 2010 bonus programs?
A: No. Because qualified registries only report data to CMS one time, you may still have the opportunity to contact a qualified registry and engage them to report on your behalf for PQRI. A list of qualified registries has been made available at the CMS website at
http://www.cms.gov/PQRI/Downloads/Qualified_Registries_Phase4_eRxPQRI_06282010_FINAL.pdf.
The Outcome PQRI Registry was recently endorsed by both the
The E-Rx bonus requires submission of 25 electronic prescriptions on a qualified system. Depending on your volume, you may still qualify if you adopt and use a qualified system 25 times before the end of December.
Q: Have the requirements been established for the HIT program?
A: They are still a work in progress, but after several months of preliminary specifications and a comment period, CMS finalized the definition of meaningful use of certified EHR technology this past July. Eligible professionals meeting the meaningful use criteria on a certified EHR system will be eligible for incentive payments beginning in 2011.
At this time, only Stage 1 Criteria have been defined. Stages 2 and 3 will build from Stage 1 but are not yet finalized. Stage 1 contains 25 objectives divided into a core set and a menu set. Successful users must meet all 15 objectives in the core set and five objectives from the menu set.
Detailed fact sheets describing the regulation have been made available at the CMS website at:
http://www.cms.gov/apps/media/fact_sheets.asp.
Q: What organizations can certify EHR software?
A: The Office of the National Coordinator for Health Information Technology, Department of Health and Human Services, announced this past August that two organizations have been named to test and certify that EHR software is able to meet the established criteria to support meaningful use. This will qualify eligible providers for the HIT bonus. The two organizations are the Drumond Group and the Certification Commission for Health Information Technology.
Q: Is there a more extensive website about EHR incentive programs?
A: Yes. CMS has dedicated a significant amount of space on their website to different types of information regarding both the Medicare and Medicaid bonus programs. You can access the information at:
http://www.cms.gov/EHRIncentivePrograms/. Visit the site frequently for important updates.
Ms. McCune is vice pres-ident of the Corcoran Consulting Group. Contact her at
DMcCune@corcoranccg.com.
