OTC Drugs via Electronic Prescribing

Time is running out for physicians to meet the electronic prescription submission requirement of ten submissions prior to June to avoid a 2012 penalty. In 2012 and beyond, eligible professionals who are not successful E-Prescribers will see a reduction in their fee schedule amounts. The reduction is 1% for 2012, 1½% for 2013, and 2% for 2014 and beyond. CMS plans to use data collected in the first six months of 2011 to determine which eligible professionals are not E-prescribers for the purpose of reducing 2012 fee schedule amounts. To avoid the 2012 penalty, each eligible provider must submit a minimum of ten electronic prescriptions between January 1 and June 30, 2011.

On May 12, 2011, CMS posted the following information about over-the-counter medications on the FAQ section of their website answering questions about E-prescribing.

Q: “If an eligible professional electronically prescribes over-the-counter (OTC) medicine, will this be counted for purposes of the Electronic Prescribing (eRx) Incentive Program?

A: If an eligible professional sends an eRx (via a qualified eRx system) to the pharmacy electronically (for a denominator-eligible visit) then the eRx event would count–even for an OTC medicine. The key is the prescription needs to be sent electronically to a receiving entity and the system needs to be able to check for the dose, and drug-drug interactions, etc., if they are available, just like for a regular eRx.”

The ability to submit an eRx for an over the counter medication may assist those providers struggling to achieve the minimum required prescriptions by June 30, 2011.