Pay 4 Reporting Update

I had the opportunity last week to speak about meaningful use and pay for reporting at the FMC Medical Directors meeting in Dallas. I thought this week I would provide a quick update related to a couple of these areas.



During last week’s PQRS Registry call with CMS we learned that the 2010 e-prescribing incentive payments have been mailed. Those of you who successfully participated in 2010 should have your incentive by now. If you participated in 2010 but have not received an incentive payment there is a good chance you were not successful. The incentive schedule for the e-prescribing program is identified in the table below:



A hot topic at the meeting in Dallas was the 2012 e-prescribing penalty. Unfortunately, in spite of the fact that the specifics of the penalty have been available for almost a year, there are still a large number of nephrologists who are unaware of the impending penalty. Earlier this month CMS added four additional hardship exemptions designed to reduce the number of providers that will be subject to the penalty in 2012. The window to attest for a hardship exemption for this penalty closes on November 1, 2011. The CMS portal to log an exemption can be found here.



During the CMS Registry call referenced above we learned the incentive checks for participating in the 2010 PQRI program are being mailed to successful participants this month. If you participated last year and have not been paid by early October you were most likely not successful. PQRI has a new name for 2011—the Physician Quality Reporting System. There have been some changes for 2011 which require our attention. The incentive schedule for PQRS is noted below:



Meaningful Use

The intersection of PQRS and e-prescribing with meaningful use remains a source of confusion. Most nephrologists who elect to demonstrate meaningful use will take the Medicare path. In this circumstance, the provider may also participate in the PQRS incentive program. However, if you demonstrate meaningful use via the Medicare path in 2011, you may not also collect the CMS e-prescribing incentive for 2011.


CMS continues to report success rates on a monthly basis. August was a busy month for meaningful use as the number of providers demonstrating meaningful use doubled. Over 72,000 providers have registered for the Medicare path of the program through the end of August with over 2,100 receiving the year 1 incentive to date. Nephrologists remain well represented among those paid for participation via the Medicare path through August as you can see in the table below:



There was quite a bit of engagement regarding these topics at the FMC Medical Directors meeting last week. In my experience nephrologists are becoming more fluent with these important CMS programs. However, the lack of awareness surrounding the 2012 e-prescribing penalty remains troubling to me. The window for applying for one of the hardship exemptions remains open for another 5 weeks. Please join me in spreading the word to our nephrology colleagues around the country.

6 Responses to “Pay 4 Reporting Update”

  1. Of the two “original” incentive programs introduced over the last few years, I find it so hard to believe there are nephrology practices who are not participating in the e-prescribe incentive program. There are so many cheap or free e-prescribe programs out there. Our incentive for our practice more than covered the fee we paid for an e-prescribe program. Grant you some of our doctors did not have enough E&M office services to meet the threshold, but it has made our lives easier and we got paid for that. Even the doctor who writes the least amount of scripts annually got incentive money. For those not on an EMR who are not e-prescribing you are leaving money on the table. Our e-prescribe incentive money is helping us pay for our EMR.

    1. Peggy, I agree with you. The eRx program has been “low hanging fruit” for the past year or two. As I have traveled across the country there remain a large number of folks either unaware of the program or electing not to implement eRx. A greater percentage of nephrologists are in the dark when it comes to the penalty phase of the e-prescribing program. Those provider’s using a certified EHR of course have access to an e-prescribing tool. Those who do not may wish to take a look at the Surescripts web site which does a reasonable job of aggregating the list available eRx tools.
      I also agree the eRx program is the easier of the two CMS P4R programs. Unfortunately most nephrologists with a certified EHR must choose either to demonstrate meaningful use or pursue the eRx incentive, unless they are eligible for the Medicaid path to meaningful use. Thanks for your comment Peggy.

  2. Terry, Thanks for the link to the CMS portal to record our exemption. It took about 30 to 40 minutes get our 5 providers signed up for this exemption. One needs all kind of goodies handy—the EMR cert #, the NPI number, the TIN number.

    It is not clear what NPI number I should have put in. Should I put in the one for the practice? Should I put in the one for the individual?

    It is nice that we can receive a feedback report on the ERx program and PQRS program. I have requested that for each provider.

    Also, I love the new website design. Compliments to the designers of it!

    We did not receive the ERx bonus, but do not know why. Hopefully the answer will be on the feeback report.

    1. Thanks Randy. My understanding is that you should use the providers individual NPI number as the programs are provider specific.

  3. This morning I received the feedback report on all of the doctors for the PQRS and ERx incentive programs. It is worthwhile to check these boxes to get the report. The data is fairly robust and specific. I was impressed with how quickly they sent me the “feedback” report. For some reason, however, on the PQRS, they sent me the 2009 program year, not the 2010 year. Perhaps the 2010 data is not yet compiled. I did not get any information as to whether or not our exemptions were granted for the meaningful use part of the ERx program. Regulatory buffs out there, go ahead and fill out the form from the link below, it is worth the 10 minutes per provider to complete.

    1. One of our blog readers notes the provider must actually submit the hardship exemption. Per this FAQ on the CMS web site office staff may not submit the hardship exemption on behalf of the physician.

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