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Coming in January 2012

Watch for New Remittance Advice 'Remark Codes' Related to E-Prescribing

By Sheri Porter

"If physicians aren't certain whether or not they were successful electronic prescribers (e-prescribers) in 2011, the answer may be coming on Jan. 1 when the penalty phase of Medicare's e-prescribing incentive program kicks in," Cynthia Hughes, C.P.C., an AAFP coding and compliance specialist, recently told AAFP News Now.
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According to Hughes, a new remittance advice "remark code" that relates to the e-prescribing penalty was highlighted in CMS' Sept. 15 MLN Matters (3-page PDF; About PDFs), the agency's online publication designed to help keep Medicare fee-for-service providers informed.

CMS said the new remark code is effective on Oct. 1, but physicians won't see the code on remittance advices until Jan. 1, 2012. That's when physicians who did not successfully e-prescribe in 2011 will begin to see a 1 percent penalty amount subtracted from each Medicare remittance advice that comes back from their Medicare contractors.

In addition to the remark code indicating the assessment of a payment penalty, CMS has added a remark code to reflect the repayment of money withheld in error. Specifically, the remark codes and their descriptions are
  • N545, which would indicate that the physician's payment was reduced based on his or her status as an unsuccessful e-prescriber per the Medicare e-prescribing incentive program, and
  • N546, which would indicate that the payment represents a "give-back," or return of a previous e-prescribing penalty amount that was deducted in error.
"At this point in time, there's not much a practice can do regarding penalties on their 2012 payments (which are based on 2011 claims) except adjust their 2012 budgets accordingly," said Hughes. The impact of the reduction depends on the percent of a physician's revenue that is generated by Medicare services. For many, this may be negligible," she added.

There still is plenty of time for physicians to begin e-prescribing in 2012 and avoid future penalties. The penalty in 2013 will be 1.5 percent of total Medicare revenues; in 2014, the penalty increases to 2 percent.

With regard to other Medicare resources, CMS has provided three online links to resources physicians may find useful. Specifically, the agency has
  • posted the form that physicians must fill out to request an exemption from Medicare's e-prescribing penalty;
  • made available a manual (17-page PDF; About PDFs) that provides directions on how physicians can obtain their Physician Quality Reporting System, or PQRS, feedback reports; and
  • created a manual (17-page PDF; About PDFs) to help physicians understand their e-prescribing feedback reports.
In addition, CMS announced on Sept. 27 that it will host a national provider call on two topics: the PQRS and the e-prescribing incentive program.

The call is set for Oct. 18 from 1:30-3 p.m. EDT and will target physicians and medical office personnel, medical coders, and other health care professionals. The event includes a question-and-answer segment. CMS will post registration information soon, or physicians can sign up to receive automatic e-mails regarding open-door forum schedule updates.


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