DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 1279
incentive payment under the EHR Incentive Program with respect to a certified EHR
technology that has the capability of electronic prescribing.
We will, however, be developing a plan, as described under section 1848(m)(7) of
the Act ("Integration of Physician Quality Reporting and EHR Reporting"), to integrate
measure reporting requirements under the Physician Quality Reporting System, eRx
Incentive Program, and the EHR Incentive Program, with respect to selection of measures
to demonstrate meaningful use under the EHR Incentive Program, quality of care
furnished to an individual, and such other activities as specified by the Secretary.
With regards to the commenters’ statement that the eRx payment adjustment still
applies even if an eligible professional participates in both programs, this is not accurate.
The eRx payment adjustment applies only to the extent that the eligible professional is
not a successful electronic prescriber. We would also like to clarify that the limitation
under section 1848(m)(2)(D) of the Act with respect to EHR incentive payments does not
preclude the 10 percent limitation under section 1848(m)(2)(B)(i) of the Act from
applying with regard to the eRx payment adjustment to an eligible professional who earns
an EHR incentive.
Comment: One commenter requested that we clarify the way in which we intend
to calculate the group eRx incentives if individual members of the group have received
Medicare EHR incentives.
Response: We will assess the group practice's data first to determine eRx
incentive eligibility. If the group practice is eligible for an eRx incentive, then we will
filter out the allowed charges for all NPIs who earn an EHR incentive before calculating
the group's incentive amount.