Electronic Health Record-based (EHR-based) Reporting

50.3 – Electronic Health Record-based (EHR-based) Reporting Mechanism (Rev. 10, Issued: 07-27-12, Effective: 10-29-12, Implementation: 10-29-12) Beginning with the 2010 eRx Incentive Program, Individual eligible professionals and group practices may choose to participate in the eRx Incentive Program via the EHR-based reporting mechanism for all reporting periods except those 6-month reporting periods associated with a payment adjustment. Beginning in 2012, as described in further detail in Chapter 1, section 50.3, eligible professionals and group practices may participate in the eRx Incentive Program via two EHR-based reporting mechanisms: (1) a qualified direct EHR or (2) a qualified EHR data submission vendor. Eligible professionals and group practices that choose to participate in the eRx Incentive Program via the EHR-based reporting mechanism do not have to enroll or register to begin EHR-based reporting of the eRx measure to CMS. Likewise, eligible professionals and group practices that choose to participate in the eRx Incentive Program via EHR data submission vendors do not have to enroll or register to begin EHR-based reporting of the eRx measure to CMS. However, to report eRx measure data via the EHR-based reporting mechanism, an eligible professional or group practice must select a qualified EHR product. An eligible professional or group practice choosing the EHR-based reporting mechanism must: • Have an active Individuals Authorized Access to CMS Systems (IACS) user account that will be used to submit the eRx measure data extracted from the EHR to CMS; • Submit a test file containing real or dummy clinical quality data extracted from the EHR to a CMS clinical data warehouse; and • Submit a file containing the eligible professional’s or group practice’s eRx measure data extracted from the EHR for the entire reporting period via IACS by no later than 2 months after the end of the reporting period. (For the 2010 incentive, the submission period will be 02/01/11 – 03/31/11). Only an EHR product that is qualified for use by eligible professionals to submit Physician Quality Reporting System quality measures information to CMS is eligible to become a qualified EHR product for the purpose of an eligible professional or group practice using the product to submit eRx measure information to CMS. CMS qualifies EHR vendors and their specific product(s) for use by eligible professionals to submit Physician Quality Reporting System quality measures data to CMS (see Chapter 1, 17 §50.3). The list of qualified EHR direct and data submission vendors and their qualified products for a specific program year are made available on the CMS eRx Incentive Program website at http://www.cms.gov/ERXincentive. Please note that, for all 6-month reporting periods associated with a payment adjustment, only the claims-based reporting mechanism may be used for purposes of the eRx payment adjustment. For example, for purposes of the 6-month reporting period for the 2013 payment adjustment (i.e., January 1, 2012-June 30, 2012, only the claims-based reporting mechanism may be used for purposes of the 2013 eRx payment adjustment even though the EHR-based reporting mechanism was finalized for use by eligible professionals for the 12-month reporting period for the 2013 payment adjustment (i.e., January 1, 2011 – December 31, 2011) and for purposes of the reporting period for the 2012 incentive (i.e., January 1, 2012-December 31, 2012). As such, to the extent an eligible professional intended to use an EHR or EHR data submission vendor to submit eRx measure data for purposes of qualifying for the 2012 eRx payment incentive, the eligible professional would still need to submit eRx measure data on claims for services furnished between January 1, 2012 and June 30, 2012, in order to avoid the 2013 eRx payment adjustment unless the eligible professional was a successful prescriber for the 12-month 2011 reporting period or a hardship exemption or other exclusion applies.