The Medicare program has traditionally been unable to notify providers participating in the Medicare electronic prescribing incentive program if they have qualified for incentive payments until the year following their participation.

That long timetable won't cut it now that the meaningful use incentive program starts in 2011, according to the Medical Group Management Association. The Englewood, Colo.-based organization recently sent a letter to the Centers for Medicare and Medicaid Services commenting on multiple provisions of the proposed rule setting the Part B physician fee schedule for 2011.

There exists significant overlap between the 2011 Medicare eRx initiative and the 2011 Medicare EHR incentive program, according to the comment letter.  Because of the long delay in providing feedback on to e-prescribing physicians, "it will be extremely challenging for providers to determine if they have qualified for one or both of these incentive programs in a timely manner."

Consequently, MGMA expects many providers will apply for both incentive programs in 2011. "As eligible professionals are not eligible to receive payments from both programs in 2011, it is critical that CMS accurately and quickly ascertains if an eligible professional has successfully completed all requirements for either program, and expediently report the results to the eligible professional," the association advises.

MGMA concurs with a number of changes proposed in 2011 for the Physician Quality Reporting Initiative, including a new option that would eliminate redundant measure reporting by multiple providers in the same practice treating the same patient.

But the association warns against premature discontinuation of claims-based PQRI reporting. "Many participants have struggled and finally achieved success via this reporting option," according to the comment letter. "CMS should continue offering multiple reporting mechanisms, including the option of reporting via the claims-based method, for several years."

MGMA also urges CMS not to list on the Physician Compare Web site providers who unsuccessfully participated in PRQI, along with successful providers. That would serve as a barrier to practices contemplating participation, according to the association.

--Joseph Goedert


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