More and more electronic medical record (EMR) programs now integrate electronic prescribing (e-prescribing). And it's a good thing they do. The Medicare Improvements for Patients and Providers Act (MIPPA) took effect in January, and this law offers financial incentives for the implementation of e-prescribing systems.

E-prescribing allows providers to transmit new prescriptions and pharmacy refill requests electronically. The law offers incentives for e-prescribing, as long as prescribers comply with set requirements. Conversely, to prescribers who do not establish e-prescribing practices, Medicare will provide "differential payments" that equal penalties. Table 1 provides an overview of the incentives vs. penalties.

Background
E-prescribing has been around for many years, but it has been interpreted many ways. The Centers for Medicare and Medicaid Services (CMS) provided its explanation in the final regulations for MIPPA: "E-prescribing means the transmission, using electronic media, of prescription or prescription-related information between a prescriber, dispenser pharmacy benefit manager, or health plan, either directly or through an intermediary, including an e-prescribing network. [It] includes, but is not limited to, two-way transmissions between the point of care and the dispenser."

CMS has identified the professionals it deems eligible for the e-prescribing incentives and penalties, and nurse practitioners are among them. So how do you begin?

Get a Qualified System
The Certification Commission for Healthcare Information Technology (CCHIT) is the certification authority for EMR networks. CCHIT is responsible for development and evaluation criteria. As of March 2009, however, e-prescribing programs are not evaluated by CCHIT or any other agency. How do you choose?

Step 1
First, decide which type of e-prescribing systems you will use: a stand-alone system or a full EMR with e-prescribing. A stand-alone system can be a bridge to integration with full EMR. Benefits of a stand-alone are that implementation time is relatively short, minimal training is needed, and monthly subscription costs are low. A full EMR with e-prescribing can address the entire workflow of a practice. It integrates scheduling, charting, billing and e-prescribing into one paperless system. Implementation time for a full EMR is longer than with stand-alone e-prescribing, and the financial investment is more significant.

Step 2
Second, examine the specific features of the system you are considering. Does it follow Medicare Part D standards? Will the system be updated as needed to meet CMS requirements? Does it generate a complete medication list that can incorporate data from pharmacies? Does it select medications, transmit prescriptions electronically using current requirements and warn of adverse interactions or other possible undesirable or unsafe situations? Does it provide information on lower-cost, therapeutically appropriate alternatives (e.g., tiered formulary information, if available)?

If the network you choose converts the electronic prescription into a paper fax because the pharmacy can't receive electronic faxes, this will count as e-prescribing. But if the e-prescribing system is capable only of sending a fax directly from the e-prescribing system to the pharmacy, the system is not a qualified e-prescribing system. Detailed system requirements are available at http://cms.hhs.gov/pqri. Select "E-prescribing Incentive Program."

Step 3
After you have implemented an e-prescribing system, report your compliance with the incentive program. Successful e-prescribers -- those who qualify for the Medicare incentives -- must report on the e-prescribing quality measure using the two components described in Table 1.

Encouraged, Not Required
CMS does not require enrollment in the e-prescribing incentive program, but prescribers who do not participate will experience the lower reimbursements shown in Table 2.

The average stand-alone e-prescribing system costs $750. Monthly fees for subscription and maintenance average around $50. Providers can accept donations for the purchase of e-prescribing technology, but they cannot violate the Stark law or the antikickback statute. Donations typically come from sources such as hospitals.

Revised and additional standards for e-prescribing under Medicare Part D are expected this year. It is imperative that your e-prescribing system can update to meet the required standards. Some requirements for e-prescribing are state-specific. Contact your state officials to ensure compliance.

Putting It Into Practice
The MIPPA is an incentive program that can provide benefits if you do the following:

• study the requirements and investigate options for software
• educate providers and billing staff about denominator codes and new G codes
• report the quality measures on 10% of Medicare revenue (denominator code plus appropriate G code on more than half of cases for numerator).

The 5-year incentive payments provided by CMS can help offset implementation fees for e-prescribing and a full EMR program with an e-prescribing component. E-prescribing provides clinical enhancements by including drug-drug adverse interactions, problem lists, integration with EMR and a bridge to future EMR integration. E-prescribing complements full EMR and contributes to total patient record.

From small solo practices to multiprovider groups, e-prescribing is a tool that benefits both patients and practices.

Vanessa Best is a certified professional coder who is the president and CEO of Precision HealthCare Consultants in Baldwin, N.Y. For more information on MIPPA, e-mail her at vbest@precisionhcc.com.