Exception Relating to Electronic Prescribing Information
CMS's
regulatory proposal creates an exception to the physician self-referral
prohibition in the Stark law for certain arrangements in which a
physician receives necessary non-monetary remuneration that is used
solely to receive and transmit electronic prescription drug information.
CMS's
proposed rule protects the donation of qualifying electronic
prescribing technology when the donation is made by hospitals to members
of their medical staffs, by group practices to their physician members,
and by prescription drug plan sponsors and Medicare advantage
organizations to physicians. CMS is considering whether to limit the
aggregate fair market value of all items and services provided to a
physician from a single donor. CMS believes a monetary limit is
appropriate and reasonable to minimize the potential for fraud and
abuse, and is soliciting public comment on the amount of the cap.
The
proposed exception would protect only items or services that are
"necessary" to conduct electronic prescription drug transactions. This
might include, for example, hardware, software, broadband or wireless
Internet connectivity, training, information technology support
services, and other items and services used in connection with the
transmission or receipt of electronic prescribing information. CMS
believes the exception would allow a hospital to provide a physician
with a hand-held device capable of transmitting electronic prescribing
information, even though the physician may already have a desktop
computer
that could also be used to send the same information. However, the
proposed rule would require the physician to certify that items and
services provided are not technically or functionally equivalent to
those that the physician already possesses or has already obtained.
In
addition, to be eligible for the exception, the items and services must
be "used solely" for the transmission or receipt of electronic
prescribing information. However, CMS is proposing to create an
additional exception to protect the provision of hardware and
connectivity service that are used for more than one function, so long
as a substantial use of the item or service is to receive or transmit
electronic prescription information. CMS is soliciting comments on
methodologies for quantifying or ensuring that a substantial use of
hardware and connectivity services is for the receipt or transmission of
electronic prescribing information.
Exception Relating to Electronic Health Records
I am not getting paid when I submit HCPCS code J3490 with the drug name and NDC number. Why? Answer: HCPCS code J3490 is a ...