Just in time for the deadline, CMS defines the 10% threshold needed to earn the e-prescribing (e-Rx) bonus in the FAQ and updated others, which could put some of your concerns to rest.

What is meant by the 10% threshold check for the 2011 Electronic Prescribing (e-Rx) Incentive Program?

At least 10% of your Medicare Part B allowable charges must be comprised of codes from the CPT/G-codes in the measure's denominator as part of the e-prescribing requirement (NPP 6/27/11).

CMS will add all of an eligible professional's Part B allowable charges for services that appear in the denominator of the measure and divide this sum by his/her entire Medicare Part B book of business for the year. If this fraction is less than 10%, the eligible professional will not receive the 1% incentive even if the required number of prescriptions were sent electronically.

Please note that an eligible professional cannot earn an incentive in both the Electronic Prescribing Incentive Program and the Medicare EHR Incentive Program, as these two programs are mutually exclusive.

An eligible professional can, however, be subject to a payment adjustment in 2012 for not reporting at least 10 e-Rx events via claims in the first six months of 2011. To avoid the 2012 e-Rx Payment Adjustment, an eligible professional must report (via claims) that at least one prescription for Medicare Part B FFS patients created during an encounter that is represented by one of the codes in the denominator of the 2011 e-Rxmeasure was generated and transmitted electronically using a qualified e-Rx system at least 10 times during the 2012 e-Rx Payment Adjustment reporting period (that is, January 1, 2011 through June 30, 2011). An eligible professional is excluded from the payment adjustment if any of the following apply:

• The eligible professional does not clear the 10% threshold in the first six months of the 2011 e-Rx reporting period (January 1-June 30, 2011);
• The eligible professional has fewer than 100 encounters defined by the e-Rx denominator codes with Medicare Part B patients in the first six months of 2011;
• The eligible professional does not have prescribing privileges;
• The eligible professional practices in a rural area without sufficient high-speed Internet access; or
• The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing.

The last two are considered hardship exemptions and will require the provider to submit a new G-code on an eligible claim during the first six months of the year attesting to the hardship. If you are an MD, DO, PA, or NP and you do not electronically prescribe at least 10 times in the first six months of 2011, you may see your Medicare Physician Fee Schedule drop in 2012 to 99% of the 2012 PFS.

Here’s an updated e-Rx/Physician Quality Reporting (PQRS) question addressing whether or not an EHR system is needed to participate in the programs:

Do practices need to have and use an electronic health record (EHR) in order to participate in the Physician Quality Reporting System (Physician Quality Reporting, formerly called PQRI) or the Electronic Prescribing (e-Rx) Incentive Program?

No. Practices do not need electronic health records (EHR) to participate in Physician Quality Reporting or the e-Rx Incentive Program. If a practice does have an EHR system that has the capability to interface with its practice management system, these systems may be modified to capture quality-data codes for submission through claims, qualified registry, or qualified EHR.

Click here for the rest of CMS’s e-Rx FAQs.