Out Clause for Phlebology
by AJ Riviezzo
One of the new(er) concerns we have been fielding of late is the Medicare decision on E-prescribing. Medicare is turning it from a small bonus to a penalty if you are not in compliance. While the 1% reduction for next year isn’t large, it will increase each subsequent year.
On to the good news though. The Federal Register, Vo. 76, No. 105 dated June 1, 2011, page 31550 states:
“…the 2012 eRx payment adjustment does not apply to an individual eligible profession or group practice if less than 10 percent of an eligible professional’s or groups practice’s estimated total allowed charges for the Jan 1, 2011 through June 30, 2011 reporting period are comprised of services that appear in the denominator of the 2011 eRx measurer.”
In summary, if your services for certain codes are less than 10% of what Medicare pays you for all of your Medicare reimbursed services, the E-Prescribe requirements do not apply. There are multiple codes but the primary ones for a phlebology practice are the 99201-99205 new patient exams and 99211-99215 office visit exams. Please contact me if you would like a copy of all of the codes (877.274.2313).
We reviewed three different phlebology practices to see if they came close to the 10% mark. Out of the three, the highest percentage was 4% with the other two less than half of that. Essentially, unless your practice was only seeing new patients and not providing US services or treatment, you likely fall well under the 10 percent mark as well. You may want to double check this assumption but I feel pretty confident that this rule will not apply to phlebology practices as it is currently written.
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