DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 1265
patient visit. The commenter noted that a vast majority of prescriptions in an internal
medicine or family practice office are generated outside of a patient visit through the
prescription renewal workflow while new prescriptions – the minority – are often
coincident with the patient visit. The commenter believes that this sets up a cascade of
filters that may prevent many otherwise successful providers from meeting the
denominator criteria. The commenter stated that pharmacies either have, or can easily
acquire, the capability to report the manner in which the prescription was received and
CMS should consider a determined number of pharmacy claims of electronic
prescriptions for Medicare beneficiaries, where the prescriber and manner of prescription
delivery are clearly defined, as acceptable minimum criteria to determine a successful
electronic prescriber. The commenter believes that the infrastructure to support this is
laid in the requirements that Medicare D claims be submitted electronically to CMS and
would allow CMS to identify successful electronic prescribers independent of the office-
generated claims.
Response: As we stated in the proposed rule (75 FR 40203), we believe that the
completeness and accuracy of the Part D data with respect to whether a prescription was
submitted electronically is unknown, which is why we are continuing to require reporting
on an electronic prescribing measure. As stated previously, we welcome suggestions for
additional denominator codes for use in future years but believe that the existing
denominator codes are generally representative of the types of services in which
prescriptions are often generated.
Comment: One commenter supported the proposal to "expand the scope of the
denominator codes for 2010 to professional services outside the professional office and