ARE RHCS EXEMPT FROM eRx bonus and penalties?
Oct 31, 2011
ARE RHCS EXEMPT FROM eRx bonus and penalties?
From CMS FAQ:
"How is "place of service" (POS) analyzed for the Physician Quality Reporting System (Physician Quality Reporting, formerly called PQRI) and the Electronic Prescribing (eRx) Incentive Program?
Denominator analysis will ignore line items with POS 50 (Federally Qualified Health Center or FQHC), 72 (Rural Health Center or RHC), and 81 (Independent Diagnostic Testing Facility). These three POS codes are also not used in incentive payment calculations. If you are an eligible professional, work exclusively at any of these facilities, and bill Medicare Part B with one of these POS codes, you unfortunately are unable to participate in Physician Quality Reporting or the eRx Incentive Program. You would also be exempt from eRx payment adjustments."
NARHC Response from Bill Finerfrock
First, I want to reiterate that RHC claims are not subject to the e-prescribing bonus OR penalty.
Physicians, PAs, NPs working in the RHC are not subject to the e-prescribing bonus or penalty for services they provide in the RHC.
As has been noted, however, sometimes an RHC physician, PA or NP might provide non-RHC services for which a Part B claim is generated (such as a hospital visit). This has caused some to wonder whether these non-RHC services could be of sufficient volume to trigger an e-prescribing penalty.
CMS has determined that there are two Part B claims-based threshold tests for determining whether a provider would be subject to the e-prescribing penalty:
The provider has more than 100 cases containing an encounter code in the measure denominator.
Or
less than 10% of an eligible professional's (or group practice) allowed charges for the January 1, 2011 through June 30, 2011 reporting period are comprised of codes in the denominator of the 2011 eRx measure.
This raises the obvious question, just what is "in the denominator of the 2011 eRX measure."
CMS has identified certain CPT codes that are "in the denominator of the measure". In other words, these are the codes that will be looked at to determine qualification or penalty. The codes that CMS has identified as "denominator" codes are:
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99345, 99347, 99348, 99349, 99350,
If your physicians, NPs or PAs submit at least 100 Medicare Part B claims (claims submitted using the 1500) with the above referenced CPT codes, then they could be subject to the e-prescribing penalty.
If your physicians, NPs or PAs submit MORE than 100 Medicare Part B claims with the above referenced CPT codes AND this number represents more than 10% of the Part B claims they submitted, then they could not be subject to the e-prescribing penalty.
For the most part, the above codes are the E&M codes (new and established patients) used for traditional Part B fee-schedule claims, codes used for services provided in a nursing home or patients home, codes for psychiatric/behavioral health and codes for ophthalmology.
Hospital Service codes are not listed as being "denominator" codes.
I hope this is helpful.
Bill
Bill Finerfrock
NARHC
202-544-1880
bf@capitolassociates.com<mailto:bf@capitolassociates.com>
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