Exemptions already are available for rural practices with limited high-speed Internet access, or in an area with limited available pharmacies for e-prescribing, or with EPs generating less than 100 prescriptions during a six-month reporting period, or in a practice unable to electronically prescribe because of laws or regulations.
The new exemptions are intended to accommodate eligible professionals and group practices participating in the electronic health records meaningful use program for the first time. When EPs adopt electronic health records, they generally don’t beginning using the e-prescribing module until the EHR has been fully implemented. But because of varying reporting periods for both incentive programs, EPs that choose a 90-day EHR incentive program reporting period later in the year may have to use two e-prescribing systems--a standalone system for eRx and a certified EHR for meaningful use--which could be a financial burden.
“Alternatively, such eligible professionals who wish to use CEHRT (certified EHR) for purposes of participating in both programs may potentially have to adopt and implement CEHRT well in advance of their 90-day EHR reporting period in order to meet an earlier reporting period for the eRx Incentive Program,” according to the rule.
Consequently, CMS is proposing two new hardship exemptions to the eRx program, meaning an eligible professional or group practice would not face financial payment penalties for non-participation. The exemptions would be available to EPs and practices that achieve meaningful use during certain eRx payment adjustment reporting periods; or that demonstrate intent to adopt a certified EHR and participate in the meaningful use program by registering for the program.
The language outlining the new proposed exemptions starts on page 264 of the rule, available here.