Two federal incentive programs met through a combination of Medicare payment incentives and penalties to encourage caregivers to go digital with some aspect of their practice will overlap for three years. Since the criteria for satisfying two programs aren't the same, physicians in particular face the possibility of being penalized by one program even as they're incentivized by another, says a Government Accountability Office report dated Feb. 17.

The two programs are the Electronic Prescribing Program, which will assign penalties to caregivers who don't at least sometimes use a computer system to prescribe medication starting in 2012 through 2014, and the Electronic Health Records Program, which starts assigning penalties in 2015 until forever to providers who fail to demonstrate a "meaningful use" of EHRs.

Of course, physicians (though not hospitals) are required by current meaningful use rules to generate and transmit prescriptions. But, EPP and EHR don't measure compliance in the same way, meaning that a physician enrolled in the EHR incentive program could face a penalty from the EPP program, unless the practice submits two sets of reports to the Centers for Medicare & Medicaid Services, the GAO says.

CMS will start in 2012 penalizing Medicare payments by 1 percent for lack of an electronic prescribing system, raising that incrementally to 2 percent in 2014. Thereafter, congressional authorization for the program dies out. The EHR penalty starts at 1 percent in 2015 and stabilizes at 3 percent in 2017 and onward.

CMS officials told GAO auditors they plan on studying methods to integrate the two programs, but that the earliest it will come up with a plan is on Jan. 1, 2012. If that's the case, then physicians will still face the prospect of dual reporting, the GAO report says, because any rule that would align the two programs in 2013 would have to be finalized in November 2011.

The report also notes that physicians who invest in an electronic system for prescriptions, independently of an integrated EHR, face the prospect of reimbursement penalties, regardless, since unlike EHRs, there is no official EPP certification.     

For more:
- download the report, GAO-11-159 (.pdf)

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