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CMS-1503-FC 1300<br />

including the proposed criteria <strong>for</strong> successful reporting of the electronic prescribing<br />

measure <strong>for</strong> group practices, and our proposed analytical approach.<br />

Comment: One commenter suggested that we lower the reporting criteria <strong>for</strong><br />

group practices if we finalize our proposal to use the 6-month reporting period beginning<br />

January 1, 2011 to determine whether a group practice is subject to the 2012 payment<br />

adjustment. The commenter noted that in determining the volume <strong>for</strong> the group incentive<br />

payment, we assume that not all eligible professionals in the practice would be<br />

electronically prescribing. The commenter believes that the same assumption should be<br />

applied <strong>for</strong> purposes of the payment adjustment determination.<br />

Response: As we stated in the proposed rule (75 FR 40209), we do not believe<br />

that group practices would be disadvantaged by having to satisfy the criteria <strong>for</strong> being a<br />

successful e-prescriber <strong>for</strong> the 2011 eRx incentive in 6 months to avoid the 2012 eRx<br />

payment adjustment. When compared to the criteria <strong>for</strong> individual eligible professionals<br />

reporting the electronic prescribing measure <strong>for</strong> purposes of the payment adjustment, the<br />

criteria <strong>for</strong> being a successful electronic prescriber <strong>for</strong> the 2011 eRx payment adjustment<br />

<strong>for</strong> group practices enable group practices, on average, to avoid the incentive by<br />

electronically prescribing a fewer number of prescriptions per eligible professionals than<br />

what individual eligible professionals are required to do. There<strong>for</strong>e, we are not lowering<br />

the reporting criteria <strong>for</strong> successful electronic prescribers <strong>for</strong> purposes of determining<br />

applicability of the 2012 eRx payment adjustment to group practices. By having the<br />

same reporting criteria <strong>for</strong> purposes of both the payment adjustment and incentive<br />

payment, group practices have the added advantage of knowing that they have<br />

successfully electronically prescribed <strong>for</strong> purposes of the 2011 incentive payment once

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