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Stacking CMS Incentive Programs

Several of you have asked recently if eligible professionals can participate in the 2011 Physician Quality Reporting System ("PQRS"), 2011 eRx Incentive Program, and the EHR Incentive Program all at the same time and earn incentives for each, so we thought we would address this issue.

To be clear, the PQRS, eRx Incentive Program, and EHR Incentive Programs are three distinctly separate CMS programs. With regard to the PQRS, this incentive can be received regardless of an eligible professional's participation in the other programs.

There are three ways to participate in the EHR Incentive Program: (1) through Medicare; (2) Medicare Advantage; or (3) Medicaid. If participating in the EHR Incentive Program through the Medicaid option, eligible professionals are also able to receive the eRx incentive. If participating in the Medicare or Medicare Advantage options for the EHR Incentive Program, eligible professionals must still report the eRx measure to avoid the penalty but are only eligible to receive one incentive payment. Eligible professionals successfully participating in both programs will receive the EHR incentive payment.

Eligible professionals should continue to report the eRx measure in 2011 even if their practice is also participating in the Medicare or Medicare Advantage EHR Incentive Program because claims data for the first six months of 2011 will be analyzed to determine if a 2012 eRx payment adjustment will apply to the eligible professional.

If an eligible professional successfully generate and reports electronically prescribing 25 times (at least 10 of which are in the first 6 months of 2011 and submitted via claims to CMS) for eRx measure denominator eligible services, (s)he would also be exempt from the 2013 eRx payment adjustment.

For more information, please see the CMS EHR Incentive Programs website at:

http://www.cms.gov/EHRIncentivePrograms.