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entitled 'Electronic Prescribing: CMS Should Address Inconsistencies 
in Its Two Incentive Programs That Encourage the Use of Health 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

February 2011: 

Electronic Prescribing: 

CMS Should Address Inconsistencies in Its Two Incentive Programs That 
Encourage the Use of Health Information Technology: 

GAO-11-159: 

GAO Highlights: 

Highlights of GAO-11-159, a report to congressional committees. 

Why GAO Did This Study: 

Congress established two CMS-administered programs-—the Electronic 
Prescribing Program and the Electronic Health Records (EHR) Program—-
that provide incentive payments to eligible Medicare providers who 
adopt and use health information technology, and penalties for those 
who do not. The Medicare Improvements for Patients and Providers Act 
of 2008 required GAO to report on the Electronic Prescribing Program. 
To do so, GAO examined how CMS determines which providers receive 
incentive payments and avoid penalties from that program and how many 
providers received incentive payments in 2009. Also, GAO was asked to 
examine how the requirements of the two programs compare. GAO reviewed 
relevant laws and regulations, interviewed CMS officials, and analyzed 
CMS data on incentive payments made for 2009, which were the most 
recent data available for a full year. 

What GAO Found: 

CMS analyzes information reported by eligible providers on their 
Medicare Part B claims—which are used to submit charges for covered 
services—to determine which Medicare providers should receive 
Electronic Prescribing Program incentive payments or be subject to 
penalties. In 2009-—the first year the program provided incentive 
payments-—CMS paid approximately $148 million in incentive payments to 
about 8 percent of the approximately 600,000 Medicare providers who 
had an applicable patient visit—that is, supplied 1 of 33 CMS-
designated services typically provided in the office or outpatient 
setting. For 2009, CMS examined Part B claims to determine whether, 
after each applicable patient visit, providers marked any one of three 
electronic prescribing reporting codes used to report information on 
the adoption and use of electronic prescribing systems. To receive an 
incentive payment that year, the provider had to report the codes for 
at least 50 percent of applicable patient visits, and at least 10 
percent of the provider’s total allowed Medicare Part B charges for 
the year had to be from the applicable patient visits. CMS made 
changes in the reporting requirements for 2010. For example, the 
agency reduced the number of reporting codes to one and required that 
individual providers report the code after at least 25 applicable 
visits, instead of for 50 percent of applicable visits. From 2012 
through 2014, the Electronic Prescribing Program will assess penalties 
on providers that do not adopt and use electronic prescribing. 
Individual providers will have to submit the electronic prescribing 
reporting code at least 10 times in the first 6 months of 2011 to 
avoid penalties in 2012. 

Although GAO found similarities in the technology and reporting 
requirements for both programs, GAO also found that the requirements 
of the two programs are inconsistent in several areas. The EHR Program 
provides incentives from 2011 to 2016 and introduces penalties 
beginning in 2015, while the Electronic Prescribing Program provides 
incentives from 2009 to 2013 and provides for penalties from 2012 to 
2014, when the program ends. Both the EHR and Electronic Prescribing 
Programs require providers to adopt and use technology that can 
perform similar electronic prescribing–related activities. However, 
the EHR Program requires providers to adopt and use certified EHR 
systems that meet criteria established by HHS, which include 
electronic prescribing–related capabilities, while the Electronic 
Prescribing Program does not have a certification requirement. As a 
result, providers have no assurance that the systems they invest in 
will meet the Electronic Prescribing Program’s requirements. 
Additionally, the two programs have established separate reporting 
requirements related to electronic prescribing, potentially requiring 
physicians-—the largest and only group of providers eligible to earn 
incentive payments in both programs—-to report to both programs from 
2011 through 2014. CMS recognizes that this duplication places 
additional burden on physicians; however, CMS is still in the process 
of developing a strategy to address this duplication. 

What GAO Recommends: 

GAO is recommending that the CMS Administrator take four actions, 
including (1) encourage physicians and other providers in the 
Electronic Prescribing Program to adopt certified technology and (2) 
expedite efforts to remove the overlap in reporting requirements for 
physicians who may be eligible for incentive payments or subject to 
penalties under both programs. CMS generally agreed with three 
recommendations and disagreed with a fourth recommendation, which GAO 
clarified based on CMS’s comments. 

View [hyperlink, http://www.gao.gov/products/GAO-11-159] or key 
components. For more information, contact Linda T. Kohn at (202) 512-
7114 or kohnl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

CMS Analyzed Medicare Part B Claims to Pay Electronic Prescribing 
Program Incentive Payments to about 8 Percent of Certain Medicare 
Providers for 2009: 

While the Requirements in the EHR and Electronic Prescribing Programs 
Are Similar in Some Cases, Aspects of These Requirements Are Not 
Consistent: 

Conclusions: 

Recommendations for Executive Action: 

Agency and External Party Comments and Our Evaluation: 

Appendix I: List of Committees: 

Appendix II: Effect of Electronic Prescribing on Quality or Cost: 

Appendix III: Scope and Methodology: 

Appendix IV: Maximum Electronic Health Record (EHR) Program Incentive 
Payments, Based on First Year of Payment: 

Appendix V: Stage-One Reporting Requirements for the Electronic Health 
Records (EHR) Program: 

Appendix VI: Comments from the Department of Health and Human Services: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Figures: 

Figure 1: Electronic Prescribing Information Flow and How Electronic 
Prescribing May Improve the Quality of Health Care Provided to 
Beneficiaries and Reduce Costs to Health Care Payers: 

Figure 2: Types of Providers Eligible to Receive Incentives and Who 
May Be Subject to Penalties under the Electronic Prescribing and EHR 
Programs: 

Figure 3: Incentives and Penalties for Eligible Providers in the 
Electronic Prescribing and EHR Programs: 

Figure 4: Electronic Prescribing and EHR Program Participation 
Scenarios and Resulting Incentive Payments and Penalties: 

Figure 5: Percentage of Medicare Providers Who Received 2009 
Electronic Prescribing Program Incentive Payments, by State: 

Figure 6: Mean Incentive Payments from the 2009 Electronic Prescribing 
Program, by State: 

Figure 7: Electronic Prescribing Program, 2009: 

Figure 8: Technology Requirement for the EHR and Electronic 
Prescribing Programs, 2011: 

Figure 9: Electronic Prescribing-Related Reporting Requirements for 
the EHR and Electronic Prescribing Programs, 2011: 

Abbreviations: 

ADE: adverse drug event: 

CDS: clinical decision support: 

CMS: Centers for Medicare & Medicaid Services: 

CPOE: computerized physician order entry: 

EHR: electronic health record: 

HHS: Department of Health and Human Services: 

HIMSS: Healthcare Information and Management Systems Society: 

HITECH: Health Information Technology for Economic and Clinical Health: 

MIPPA: Medicare Improvements for Patients and Providers Act of 2008: 

NPPES: National Plan and Provider Enumeration System: 

ONC: Office of the National Coordinator for Health Information 
Technology: 

PECOS: Provider Enrollment, Chain, and Ownership System: 

PPACA: Patient Protection and Affordable Care Act of 2010: 

PQRS: Physician Quality Reporting System: 

Recovery Act: American Recovery and Reinvestment Act of 2009: 

VA: Department of Veterans Affairs: 

VistA: Veterans Health Information Systems and Technology Architecture: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 17, 2011: 

Congressional Committees: 

According to the Department of Health and Human Services (HHS), 
widespread use of health information technology could improve the 
quality of care received by patients and reduce health care costs. One 
such technology, electronic prescribing, can be used, for example, to 
electronically transmit a prescription or prescription-related 
information between a health care provider and a pharmacy or to 
provide other technological capabilities, such as alerting a provider 
to a potential interaction between a drug and the patient’s existing 
medications. Health care providers can access electronic prescribing 
technological capabilities by adopting stand-alone electronic 
prescribing systems or electronic health record[Footnote 1] systems 
that include an electronic prescribing component. Others have reported 
that stand-alone electronic prescribing systems can cost up to $2,500 
annually per provider, and EHR systems can cost approximately $25,000 
to $45,000 per provider with additional annual costs to operate and 
maintain the system.[Footnote 2] 

Congress has established two programs, administered by the Centers for 
Medicare & Medicaid Services (CMS), that aim to increase the use of 
electronic prescribing in Medicare by providing incentive payments or 
penalties for certain providers who participate in the Medicare 
Program.[Footnote 3] The time frames for the two programs overlap, and 
each program has established the following requirements that providers 
must meet in order to receive incentive payments under Medicare and 
avoid program penalties: (1) technological requirements that specify 
the types of health care information technology providers must adopt; 
and (2) reporting requirements that describe the information that 
providers report to CMS to demonstrate that they have not only 
adopted, but also used, the requisite health care information 
technology. For both of these programs, physicians are the largest 
group of eligible providers that may earn incentive payments or be 
subject to penalties. 

The first program, established by the Medicare Improvements for 
Patients and Providers Act of 2008 (MIPPA) and referred to here as the 
Electronic Prescribing Program, provides incentive payments from 2009 
through 2013 to certain Medicare providers-—physicians and other 
health care providers, such as physician assistants and nurse 
practitioners—-who have prescribing authority and who adopt and use 
systems that meet CMS’s definition of a qualified electronic 
prescribing system.[Footnotes 4,5] From 2012 through 2014, the program 
may apply a payment adjustment, or penalty, on the program’s eligible 
providers that do not adopt and use such systems.[Footnote 6] With 
incentive payments scheduled to end in 2013 and penalties scheduled to 
end in 2014, the Electronic Prescribing Program will cease to provide 
positive and negative incentives to encourage eligible providers to 
electronically prescribe after 2014. 

The second incentive program was established by the Health Information 
Technology for Economic and Clinical Health (HITECH) Act, as part of 
the American Recovery and Reinvestment Act of 2009 (Recovery Act). 
[Footnote 7] HITECH established a program, referred to here as the 
Electronic Health Records (EHR) Program, that provides incentive 
payments from 2011 through 2016 to Medicare physicians that adopt and 
“meaningfully use”[Footnote 8] certified EHR technology, which 
includes electronic prescribing technological capabilities.[Footnote 
9] Beginning in 2015, the EHR Program may apply a payment adjustment, 
or penalty, on eligible providers that do not adopt and meaningfully 
use certified EHR technology.[Footnote 10] 

MIPPA requires us to report on the implementation of the incentives 
for electronic prescribing established by MIPPA by September 1, 2012. 
[Footnote 11] In addition, because of the overlapping time frames of 
the programs, we were asked to obtain information on the relationship 
between the Electronic Prescribing Program and the EHR Program. As 
agreed with committee staff, our specific objectives for this report 
were to examine (1) how CMS determines which providers should receive 
incentive payments and avoid penalties from the Electronic Prescribing 
Program and how many providers received such incentive payments in 
2009, and (2) how the requirements in the EHR Program and the 
Electronic Prescribing Program compare to each other. MIPPA also 
directed us to report on information related to reductions in 
avoidable medical errors and estimated savings to Medicare resulting 
from the use of electronic prescribing. In response, we provide 
information in appendix II on how others have measured whether or to 
what extent electronic prescribing improves quality or reduces costs.
To address both objectives, we reviewed relevant provisions in MIPPA 
and the Recovery Act, and regulations and other published material 
pertaining to the Electronic Prescribing[Footnote 12] and EHR 
Programs.[Footnote 13] We also interviewed officials from CMS and from 
the Office of the National Coordinator for Health Information 
Technology (ONC) in HHS. ONC reports to the Secretary of HHS and plays 
a role in the EHR Program by establishing the standards and 
specifications that providers’ systems must meet for the EHR Program, 
coordinating with CMS on the development of the meaningful use 
criteria, and creating and administering the certification program 
that authorizes organizations to certify EHR technology. To report how 
many providers received payments in 2009, we analyzed CMS data on (1) 
2009 Electronic Prescribing Program participation as determined by CMS 
and (2) providers’ state locations.[Footnote 14] For more information 
on our data analysis, see appendix III. To ensure the reliability of 
the various data we analyzed, we interviewed CMS officials, reviewed 
CMS documentation, and conducted electronic testing to identify 
obvious errors. On the basis of these activities, we determined that 
CMS data were sufficiently reliable for our analysis. To compare the 
EHR Program and the Electronic Prescribing Program, we examined 
similarities and differences in the two programs’ technology and 
reporting requirements and identified inconsistencies that may limit 
the effectiveness of the programs. Because the EHR Program is broader 
than electronic prescribing, we focused our comparison on the 
electronic prescribing–related aspects of that program’s technology 
and reporting requirements. We also interviewed knowledgeable 
stakeholders, including officials from HHS’s Agency for Healthcare 
Research and Quality and the Department of Veterans Affairs (VA). To 
obtain information about studies that measured whether or to what 
extent electronic prescribing improves quality or reduces costs, we 
interviewed organizations, such as CVS Caremark, and reviewed 
published studies.[Footnote 15] 

We conducted this performance audit from February 2010 through 
February 2011 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Background: 

HHS and others have promoted electronic prescribing as one way to 
improve the quality of health care that beneficiaries receive and as 
one way to reduce costs. Health care costs are typically paid for by 
health care payers, such as CMS in the Medicare Program. In 
traditional, or paper-based, prescribing, health care providers that 
are licensed to issue prescriptions for drugs (e.g., physicians or 
physician assistants in some states) write a prescription, and the 
beneficiary takes that prescription to a dispenser (e.g., pharmacy) to 
be filled. In contrast, electronic prescribing consists of a licensed 
health care provider using a computer or hand-held device to write and 
transmit a prescription directly to the dispenser. Before doing so, 
the health care provider can request the beneficiary's eligibility, 
formulary,[Footnote 16] benefits, and medication history. This 
information can be used to improve quality and reduce costs. For 
example, a health care provider can use this information to avoid 
potentially adverse drug events such as drug-to-drug or drug-to-
allergy interactions and to prescribe less-expensive medications, such 
as lower-cost generic drugs. Figure 1 illustrates the flow of 
information during the electronic prescribing process and identifies 
areas in this process that may result in improvements in the quality 
of health care provided to beneficiaries and reductions in costs to 
health care payers. Appendix II provides information from studies 
measuring whether or to what extent electronic prescribing improves 
quality or reduces costs. 

Figure 1: Electronic Prescribing Information Flow and How Electronic 
Prescribing May Improve the Quality of Health Care Provided to 
Beneficiaries and Reduce Costs to Health Care Payers: 

[Refer to PDF for image: illustration] 

The provider can identify a patient’s record and enter patient 
information in the electronic prescribing system. 

The electronic prescribing system can be used to confirm or obtain the 
following information related to the beneficiary: 
* the beneficiary’s enrollment in a health plan; 
* the beneficiary’s formulary and benefits; and; 
* a list of medications previously dispensed to the beneficiary. 

The provider can update the electronic prescribing system with the 
beneficiary’s current medications and allergies. 
* Potential Quality Effects: By maintaining an updated medication 
history, the provider may be able to better monitor medication 
adherence and potential side effects. Maintaining an updated 
medication history can help prevent the prescription of duplicate 
medications and help beneficiaries transition through health care 
settings. 

To order the medication using the electronic prescribing system, the 
provider specifies certain information such as dosage, quantity, and 
directions. 
* Potential Cost Savings: By having access to formulary information, 
the provider may be able to select a less-expensive medication, such 
as a lower-cost generic drug. 

The electronic prescribing system may allow a comparison between the 
medication ordered and the patient’s information (e.g., body weight, 
age, diagnoses, and medication history) and also check the order for 
completeness. 
* Potential Quality Effects and Cost Savings: Alerting the provider to 
(a) potential contraindications, adverse reactions, or duplicate 
therapy, and (b) possible problems with the medication order such as 
missing or incorrect dosage and frequency, may prevent patient harm or 
costly medical treatments, or both. 

After reviewing any alerts provided by the electronic prescribing 
system, the provider changes the prescription or authorizes the 
prescription, or both. 

The provider can transmit the medication order electronically to the 
pharmacy. 
* Potential Quality Effects: A prescription transmitted electronically 
is not handwritten, which helps prevent errors caused by illegibility. 

Sources: GAO (data); Art Explosion (clip art). 

[End of figure] 

Eligibility for the Electronic Prescribing and EHR Programs: 

The types of Medicare providers eligible to earn incentive payments or 
who may be subject to penalties in the EHR and Electronic Prescribing 
Programs were established in statute, and although they overlap they 
are not identical. Specifically, only physicians, who are the largest 
population among each program's eligible providers, can earn incentive 
payments or be subject to penalties from both programs, but they 
cannot receive incentive payments or be subject to penalties from both 
programs during the same year. Other health care providers, such as 
nurse practitioners and physician assistants, are only eligible to 
receive incentive payments or are subject to penalties from the 
Electronic Prescribing Program[Footnote 17]. (See figure 2.) 

Figure 2: Types of Providers Eligible to Receive Incentives and Who 
May Be Subject to Penalties under the Electronic Prescribing and EHR 
Programs: 

[Refer to PDF for image: table] 

Electronic Prescribing Program: 
Eligible providers must be physicians or other providers, including 
nurse practitioners or physician assistants.[A] 

EHR Program: 
Eligible providers are physicians under the Medicare Program, the 
definition of which includes chiropractors.[B] 

Source: GAO analysis of MIPPA and the Recovery Act. 

[A] To receive incentive payments or be subject to penalties under the 
Electronic Prescribing Program, providers must have prescribing 
authority, which varies by state. Although chiropractors are 
identified as eligible providers in the Electronic Prescribing 
Program, chiropractors do not have prescribing authority and, 
therefore, are not able to earn incentive payments from the program. 

[B] See Pub. L. No. 111-5 § 4101, 123 stat. 467, 472 (adding SSA § 
1848(o)(5)(C)). Medicare physicians who perform substantially all of 
their services in hospital inpatient or emergency room settings are 
excluded from the provisions of the EHR Program. Pub. L. No. 111-5 § 
4101 as amended by the Continuing Extension Act of 2010, Pub. L. No. 
111-157, § 5, 124 Stat. 1116, 1117 (clarifying HITECH Act provision 
providing for nonapplication of EHR incentives). CMS has determined 
"substantially all" to mean 90 percent or more of the eligible 
provider's services are performed in a hospital inpatient or emergency 
room setting. See 42 C.F.R. § 495.4 (as added by 75 Fed. Reg. 44314, 
44565). 

[End of figure] 

Incentive Payments and Penalties in the Electronic Prescribing and EHR 
Programs: 

There is some overlap in the time frames for incentive payments and 
penalties for the Electronic Prescribing and EHR Programs. Incentive 
payments for the Electronic Prescribing Program are available from 
2009 through 2013. Incentive payments for the EHR Program begin in 
2011 and may be available until 2016, depending on which calendar year 
the provider initially receives an incentive payment from the program. 
Incentive payments for both programs are determined by multiplying the 
provider's total allowed charges for provider services covered by 
Medicare Part B[Footnote 18] for the year by the incentive percent 
authorized by statute. However, in the EHR Program the year in which 
the provider first adopts and meaningfully uses the EHR technology 
determines the maximum annual incentive payment a provider can earn 
and the total number of years incentive payments are available. For 
both programs, incentive payments are disbursed after providers 
demonstrate that they met the applicable program requirements. Figure 
3 displays the timeline and maximum incentive payments and penalties 
for both programs. (Appendix IV provides additional detail on the 
annual and total incentive payments an eligible provider could receive 
from the EHR Program based on the initial year the provider receives 
an incentive payment.) By law, providers cannot receive an incentive 
payment for both programs during the same year.[Footnote 19],[Footnote 
20] 

Figure 3: Incentives and Penalties for Eligible Providers in the 
Electronic Prescribing and EHR Programs: 

[Refer to PDF for image: illustration] 

Electronic Prescribing Program: 

Incentive: 
* Percentage of Part B charges: 
2009: 2%; 
2010: 2%; 
2011: 1%; 
2012: 1%; 
2013: 0.5%. 

Penalty: 
* Percentage of Part B charges: 
2012: -1%; 
2013: -1.5%; 
2014: -2.0%. 

EHR Program: 

Incentive: 
* 75 percent of Part B charges, up to a maximum amount: 
2011: Up to $18,000; 
2012: Up to $18,000; 
2013: Up to $15,000; 
2014: Up to $12,000; 
2015: Up to $8,000; 
2016: Up to $4,000; 

Penalty: 
* Percentage of Part B charges: 
2015: -1%[A]; 
2016: -2%; 
2017: -3%; 
2018+: -3%. 

Source: GAO analysis of MIPPA and the Recovery Act. 

Notes: (1) The percentages in this figure are applied to total allowed 
Part B charges for providers that meet the programs' requirements. (2) 
In the EHR Program, the total and annual incentive payment amounts 
depend on the year the provider initially receives an incentive 
payment. See appendix IV. Providers that adopt and meaningfully use in 
2015 or later receive no incentive payments, but would also not be 
subject to the penalty, which begins in 2015. (3) In the EHR Program, 
CMS will increase the incentive payments that would otherwise apply by 
10 percent each year for providers that predominantly furnish services 
in geographic areas designated as health professional shortage areas, 
such as areas that have a shortage of primary medical care. (4) In the 
EHR Program, for 2018 and subsequent years, the law provides for CMS 
to increase the penalty by 1 percentage point from the previous year, 
up to a maximum of 5 percent, if less than 75 percent of eligible 
providers meet the EHR Program's requirements. 

[A] Providers who are subject to penalties from the Electronic 
Prescribing Program in 2014 and who are subject to penalties from the 
EHR Program will face a higher penalty from the EHR Program in 2015--2 
percent instead of 1 percent. 

[End of figure] 

Penalties for the Electronic Prescribing Program and the EHR Program 
may be automatically applied to providers that fail to meet the 
programs' requirements.[Footnote 21] Penalties for the Electronic 
Prescribing Program begin in 2012 and end after 2014. Penalties for 
the EHR Program begin in 2015, and there is no statutory end-point 
provided for when the penalties will end.[Footnote 22] Since the 
Electronic Prescribing Program ends after 2014 and penalties for the 
EHR Program do not begin until 2015, providers will not receive 
penalties from both programs during the same year. However, providers 
who are subject to penalties from the Electronic Prescribing Program 
in 2014 and who are subject to penalties from the EHR Program in 2015 
will face a higher penalty from the EHR Program--2 percent instead of 
1 percent.[Footnote 23] Similar to the incentive payments, penalties 
for not adopting a program's technologies are also calculated by 
multiplying the provider's total allowed charges for provider services 
covered by Medicare Part B by the penalty percent authorized by 
statute. Penalties will be assessed by reducing the reimbursement that 
the provider would ordinarily receive for furnishing Part B services 
by the applicable penalty percentage.[Footnote 24] 

The amount of incentive payments or penalties eligible providers may 
receive depends on the year in which the provider chooses to begin 
participating in--that is, meeting the requirements of--either or, if 
eligible, both programs. In general, the earlier a provider begins 
participating in the program, the more incentive payments the provider 
will earn and the fewer penalties the provider will be assessed. 
Figure 4 below presents three scenarios of participation in the 
Electronic Prescribing and EHR Programs between 2009 and 2018. In each 
scenario, we assume that the provider is eligible for both programs 
and has $24,000 in total allowed Medicare Part B charges each year. 
[Footnote 25] 

Figure 4: Electronic Prescribing and EHR Program Participation 
Scenarios and Resulting Incentive Payments and Penalties: 

[Refer to PDF for image: illustration] 

In each scenario, the Medicare provider has $24,000 of total allowable 
Medicare Part B charges each year: 

Scenario 1: Early participation: 
The provider participates in and meets the requirements of the 
Electronic Prescribing Program beginning in 2009, earning incentive 
payments from 2009 through 2011, and avoiding penalties assessed by 
that program beginning in 2012. In 2012, the provider switches 
participation to the EHR Program and meets that program's 
requirements, earning incentive payments from 2012 through 2016 and 
avoiding penalties, which begin in 2015. 
Calendar year: 2009: Electronic Prescribing Program: $480; 
Calendar year: 2010: Electronic Prescribing Program: $480; 
Calendar year: 2011: Electronic Prescribing Program: $240; 
Calendar year: 2012: EHR Program: $18,000; 
Calendar year: 2013: EHR Program: $12,000; 
Calendar year: 2014: EHR Program: $8,000; 
Calendar year: 2015: EHR Program: $4,000; 
Calendar year: 2016: EHR Program: $2,000; 
Incentive payments/penalties: 
Electronic Prescribing Program:	$1,200; 
EHR Program: $44,000; 
Total incentive payments/penalties: $45,200. 

Scenario 2: Late participation: 
The provider participates in and meets the requirements of the 
Electronic Prescribing Program beginning in 2011, earns incentive 
payments from 2011 through 2013, and avoids penalties assessed by that 
program beginning in 2012. In 2014, the provider switches 
participation to the EHR Program and meets the program's requirements, 
earning incentive payments from 2014 through 2016 and avoiding 
penalties, which begin in 2015. 
Calendar year: 2011: Electronic Prescribing Program: $240; 
Calendar year: 2012: Electronic Prescribing Program: $240; 
Calendar year: 2013: Electronic Prescribing Program: $120; 
Calendar year: 2014: EHR Program: $12,000; 
Calendar year: 2015: EHR Program: $8,000; 
Calendar year: 2016: EHR Program: $4,000; 
Incentive payments/penalties: 
Electronic Prescribing Program:	$600; 
EHR Program: $24,000; 
Total incentive payments/penalties: $24,600. 

Scenario 3: No participation: 
The provider chooses not to participate in or meet the requirements of 
either the Electronic Prescribing Program or the EHR Program. As a 
result, the Electronic Prescribing Program assesses penalties on the 
provider from 2012 through 2014 and the EHR Program assesses penalties 
on the provider, which begin in 2015.
Calendar year: 2012: Electronic Prescribing Program: -$240; 
Calendar year: 2013: Electronic Prescribing Program: -$360; 
Calendar year: 2014: Electronic Prescribing Program: -$480; 
Calendar year: 2015: EHR Program: -$480[B]
Calendar year: 2016: EHR Program: -$480; 
Calendar year: 2017: EHR Program: -$720; 
Calendar year: 2018[A]: EHR Program: -$720; 
Incentive payments/penalties: 
Electronic Prescribing Program:	-$1,080; 
EHR Program: -$2,400; 
Total incentive payments/penalties: -$3,480. 

Source: GAO analysis of MIPPA and the Recovery Act. 

Notes: (1) See figure 3 for information on the incentive payments and 
penalties that eligible providers are subject to for both programs. 
(2) In the EHR Program, the total and annual incentive payment amounts 
depend on the initial year the provider receives an incentive payment 
from the EHR Program, and these specific amounts are provided in 
appendix IV. In the EHR Program, CMS will increase the incentive 
payments by 10 percent each year for providers that predominantly 
furnish services in geographic areas designated as health professional 
shortage areas, such as areas that have a shortage of primary medical 
care. 

[A] After 2018, providers that do not participate in or meet the EHR 
Program's requirements will continue to be assessed penalties. In the 
EHR Program, for 2018 and subsequent years, the law provides for CMS 
to increase the penalty by 1 percentage point from the previous year, 
up to a maximum of 5 percent, if less than 75 percent of eligible 
providers meet the EHR Program's requirements. 

[B] Providers who are subject to penalties from the Electronic 
Prescribing Program in 2014 and who are subject to penalties from the 
EHR Program will face a higher penalty from the EHR Program in 2015--2 
percent instead of 1 percent. 

[End of figure] 

Reporting Requirements for the EHR Program: 

CMS will develop the reporting requirements that providers will have 
to meet for the EHR Program in three stages. To date, CMS has only 
developed the reporting requirements that eligible providers will have 
to meet to receive incentive payments for the first stage, which will 
apply to providers first obtaining incentive payments from the EHR 
Program from 2011 through 2014.[Footnote 26] By the end of 2011, CMS 
expects to develop reporting requirements for receiving incentives in 
the second stage and, by the end of 2013, develop reporting 
requirements for receiving incentives in the third stage.[Footnote 27] 
CMS has stated that it may include information on the reporting 
requirements that eligible providers must meet to avoid penalties at 
the same time it issues regulations describing the third-stage 
requirements. CMS intends to make the reporting requirements more 
stringent over time as EHR technology and providers' use of that 
technology becomes more sophisticated. 

To receive an incentive payment for the EHR Program, eligible 
providers must meet or exceed a total of 20 reporting requirements 
established by CMS.[Footnote 28] Of the 20 reporting requirements, 15 
are mandatory, and providers must choose an additional 5 from a menu 
of 10 other reporting requirements.[Footnote 29] The reporting 
requirements encompass a variety of activities related to the delivery 
of health care to encourage providers to capture the following types 
of information in their EHR systems: patient demographics and clinical 
conditions, use of clinical decision support,[Footnote 30] and the 
coordination of care across health care settings. See appendix V for a 
complete list of the stage-one reporting requirements for receiving 
incentive payments. 

The reporting requirements that CMS develops for the second and third 
stages of the EHR Program may be influenced by the Patient Protection 
and Affordable Care Act of 2010 (PPACA), which directed CMS to develop 
a plan to integrate the reporting requirements used in the EHR Program 
with the information that CMS collects from eligible providers in the 
Physician Quality Reporting System (PQRS).[Footnote 31] Similar to the 
EHR and Electronic Prescribing Programs, CMS, as directed by Congress, 
implemented PQRS to provide incentive payments to eligible providers 
who satisfactorily reported data on various quality measures and 
impose penalties on those providers who did not.[Footnote 32] 
Specifically, PPACA directed CMS to develop an integration plan by 
January 1, 2012, that would identify reporting requirements that could 
be used to demonstrate meaningful use for the EHR Program and also be 
used to demonstrate quality of care provided to individuals for PQRS. 

CMS Analyzed Medicare Part B Claims to Pay Electronic Prescribing 
Program Incentive Payments to about 8 Percent of Certain Medicare 
Providers for 2009: 

To determine which providers should receive the Electronic Prescribing 
Program's incentive payments, CMS analyzes information reported by 
providers on their Medicare Part B claims, which are used to submit 
charges for covered services. To determine which providers are subject 
to penalties, which begin in 2012, CMS will also analyze information 
reported by providers on their Part B claims, but the requirements for 
avoiding penalties are different than those for obtaining incentive 
payments. In 2009, CMS paid incentive payments to about 8 percent of 
certain Medicare providers--that is, of the over 597,000 Medicare 
providers who had at least one applicable visit during 2009--and 
another 7 percent of those same Medicare providers participated in the 
Electronic Prescribing Program but did not receive incentive payments. 

CMS Analyzes Information Reported by Providers on Part B Claims to 
Determine Which Providers Should Receive Incentive Payments and Avoid 
Penalties: 

Incentive payments for the Electronic Prescribing Program are 
available from 2009 through 2013, and to determine which providers 
meet the program's requirements and should receive the payments, CMS 
analyzes information reported by providers on their Part B claims. 
[Footnote 33] Specifically, for 2009, CMS first examined 2009 Part B 
claims to determine whether, after each applicable patient visit, 
providers marked any one of three electronic prescribing reporting 
codes used to report information on the adoption and use of electronic 
prescribing systems.[Footnote 34] For 2009, the three electronic 
prescribing reporting codes were: 

* the provider had a qualified electronic prescribing system and used 
it to generate all prescriptions during the visit; 

* the provider had a qualified electronic prescribing system but did 
not use it to generate one or more prescriptions during the visit for 
one of the following reasons: the patient requested a paper 
prescription, the pharmacy could not receive an electronic 
transmission, or the prescription was for a narcotic or other 
controlled substance and could therefore not be electronically 
prescribed;[Footnote 35] and: 

* the provider had a qualified electronic prescribing system but did 
not generate any prescriptions during the visit. 

By submitting any one of the three electronic prescribing reporting 
codes to CMS, providers attested that they met the program's 
technology requirement by adopting a qualified electronic prescribing 
system and are eligible to earn incentive payments from the program. 

Second, CMS analyzed the 2009 Part B claims to determine which of the 
providers who submitted the electronic prescribing reporting codes 
also met or exceeded both components of the following reporting 
requirement:[Footnote 36] 

* the provider submitted one of the three electronic prescribing 
reporting codes at least 50 percent of the time that the provider had 
an applicable visit; and: 

* at least 10 percent of the provider's total allowed Medicare Part B 
charges for the year were from the services designated as applicable 
patient visits. 

If the provider met or exceeded the reporting requirement, CMS gave 
the provider an incentive payment for 2009, which the agency 
calculated as 2 percent of the provider's total allowed Medicare Part 
B charges for the year and by applying a small adjustment factor. 
[Footnote 37],[Footnote 38] 

For 2010, to increase the adoption of electronic prescribing 
technology, CMS made some changes to the Electronic Prescribing 
Program's reporting requirement that providers had to meet in order to 
receive an incentive payment. CMS eliminated the three electronic 
prescribing reporting codes for 2009 and replaced them with a single 
code for providers to submit to CMS. The new code indicates that after 
each applicable visit[Footnote 39] the provider generated and 
transmitted at least one prescription during the visit using a 
qualified electronic prescribing system.[Footnote 40] The agency 
stated that it believed that this change would simplify reporting. CMS 
also changed the first portion of the reporting requirement related to 
how frequently providers must submit the new electronic prescribing 
code in order to receive an incentive payment. Instead of requiring 
that providers submit the electronic prescribing reporting code at 
least 50 percent of the time that they had an applicable visit--the 
requirement in 2009--CMS required that an individual provider submit 
the new electronic prescribing reporting code for at least 25 visits. 
CMS noted that the agency believes that meeting the 2010 reporting 
requirement is achievable by a majority of eligible providers. If 
providers participated in the Electronic Prescribing Program as a 
group practice containing 200 or more providers--a new option in 2010--
the practice had to submit the electronic prescribing reporting code 
for at least 2,500 applicable visits before all of the providers in 
the practice could receive incentive payments.[Footnote 41] When it 
proposed the change to at least 25 and at least 2,500 visits for 
individual providers and group practices, respectively, CMS noted that 
it assumed that once a provider has invested in an electronic 
prescribing system, integrated the use of that system into the 
practice's work flows, and used that system to some extent, the 
provider is likely to continue to use the electronic prescribing 
system for most of the prescriptions generated. The other component of 
the reporting requirement remained unchanged from 2009: at least 10 
percent of the provider's or practice's total allowed Medicare Part B 
charges for the year were from the services designated as applicable 
visits. Finally, as an individual or as part of a group practice, 
providers could report the electronic prescribing code on their Part B 
claims, as they did in 2009, or they could do so using one of two 
alternative reporting mechanisms CMS created.[Footnote 42] 

CMS has described how it will determine which providers should receive 
incentive payments for 2011, but the agency has not yet indicated how 
it will determine which providers should receive incentive payments 
for 2012 or 2013.[Footnote 43] CMS will determine which providers meet 
the program's requirements and should receive an incentive payment in 
2011 generally using the same methods the agency used in 2010. 
However, one important change CMS made for 2011--one that is 
consistent with changes the agency is making to PQRS--is that CMS 
expanded the definition of group practice to include practices 
containing 2 through 199 individuals and will require those group 
practices to report the electronic prescribing code for a minimum of 
between 75 and 1,875 applicable visits, depending on the size of the 
group practice.[Footnote 44] The requirement for group practices of 
200 or more providers is unchanged; those practices must report the 
code for at least 2,500 applicable visits. 

From 2012 through 2014, the Electronic Prescribing Program will assess 
penalties on individual providers and group practices that do not 
adopt and use electronic prescribing. To avoid these penalties in 
2012, individual providers and group practices will have to meet 
certain reporting requirements. Individual providers will have to 
submit the electronic prescribing reporting code on their Part B 
claims for at least 10 applicable visits between January 1, 2011, and 
June 30, 2011.[Footnote 45],[Footnote 46] However, CMS will not 
penalize certain individuals in 2012 if they do not prescribe or do so 
infrequently.[Footnote 47] In addition, both individual providers and 
groups that practice in rural areas or areas with a limited number of 
pharmacies that accept electronic transmissions will be exempt from 
penalties. The reporting requirement for individuals and the exemption 
criteria are consistent with the agency's statement that it does not 
want to penalize providers with low prescribing volumes.[Footnote 48] 
Group practices will have to submit the electronic prescribing 
reporting code on their Part B claims the same number of times 
required to receive incentive payments in 2011, but they must do so 
within the 6-month period from January 1, 2011, through June 30, 2011. 
[Footnote 49] For example, group practices containing 200 or more 
providers will have to submit the electronic prescribing reporting 
code at least 2,500 times from January 1, 2011, through June 30, 2011. 
CMS has noted that it did not think that group practices would be 
disadvantaged by having to meet the reporting requirement in a 6-month 
period to avoid the penalty in 2012 rather than in a 12-month period 
to earn an incentive in 2011 because the agency requires group 
practices to submit the electronic prescribing reporting code fewer 
times on average to earn an incentive payment than it requires for 
individual providers to submit to earn an incentive payment.[Footnote 
50] 

CMS has not yet established all the requirements for providers to 
avoid penalties in 2013 or 2014.[Footnote 51] However, for 2013, CMS 
has indicated that it will not penalize individual providers or group 
practices that year if they reported the electronic prescribing code 
the minimum number of times required to qualify for incentive payments 
in 2011.[Footnote 52] Additionally, CMS indicated that it may publish 
an alternative reporting requirement that providers could meet to 
avoid penalties in 2013. A CMS official that we interviewed told us 
that the agency could, for example, require individual providers to 
submit the electronic prescribing reporting code at least 10 times 
between January 1, 2012, and June 30, 2012, in order to avoid 
penalties in 2013. 

CMS is exploring an alternative to using electronic prescribing code 
submissions to determine which providers should receive incentive 
payments or penalties. As a part of CMS's Medicare Part D, which 
provides outpatient prescription drug benefits for Medicare 
beneficiaries, CMS has required that Part D plan sponsors[Footnote 53] 
submit additional data on the claims they send to Medicare for 
reimbursement. CMS officials believe that Medicare Part D data could 
be used at some point instead of the electronic prescribing reporting 
code to determine which providers should receive incentive payments. 
[Footnote 54] However, CMS officials have concerns about the 
reliability of data from Part D claims, and note that these concerns 
should be resolved before the data can be used.[Footnote 55] CMS does 
not have specific plans or a time frame for implementing such a change. 

CMS Paid about 8 Percent of Certain Medicare Providers Electronic 
Prescribing Program Incentive Payments for 2009: 

CMS paid Electronic Prescribing Program incentive payments for 2009 to 
about 8 percent (about 47,500) of the over 597,000 Medicare providers 
who had at least one applicable visit during 2009.[Footnote 56], 
[Footnote 57] Each of these approximately 47,500 providers received 
incentive payments equal to 2 percent of their total allowable 
Medicare Part B charges in 2009, with payments totaling approximately 
$148 million. The mean payment was about $3,120, the median payment 
was about $1,700, and the five highest payments were between about 
$54,500 and $67,500. CMS disbursed these payments to providers for 
2009 in September and October 2010. CMS officials expect that the 
number of Medicare providers reporting the electronic prescribing 
reporting code in 2010 will increase over 2009 and noted that lowering 
the reporting requirement for 2010 to submitting the applicable 
electronic prescribing reporting code for at least 25 visits may 
increase the number of providers receiving incentive payments. CMS 
officials also told us that the penalties, which do not begin until 
2012, might have a bigger effect on participation than the incentive 
payments. 

For the 2009 Electronic Prescribing Program, the percentage of 
Medicare providers who received incentive payments and the average 
incentive payment varied by state. (See figure 5 and figure 6.) 
Although Minnesota and Wisconsin had the largest share of providers 
receiving incentive payments at about 17 and 15 percent, respectively, 
providers in those two states also received the lowest mean incentive 
payment at about $740 and $1,500, respectively. Alaska and North 
Dakota had the smallest share of providers receiving incentive 
payments at about 2 percent each. Providers in Florida and South 
Carolina had the highest mean incentive payments at about $5,800 and 
$4,700, respectively. According to a report prepared for CMS about the 
2009 Electronic Prescribing Program, the physician specialties with 
the largest number of providers that earned incentive payments were 
family practice and internal medicine, and the nonphysician 
specialties with the largest number of providers that earned incentive 
payments were nurse practitioners and physician assistants.[Footnote 
58] 

Figure 5: Percentage of Medicare Providers Who Received 2009 
Electronic Prescribing Program Incentive Payments, by State: 

[Refer to PDF for image: illustrated map of the U.S.] 

Nationally, about 47,500 providers (about 8 percent) received 
incentive payments. 

Less than 5%: 
Alaska: 
Arizona: 
Colorado: 
District of Columbia: 
Hawaii: 
Kentucky: 
Nevada: 
New Hampshire: 
New Mexico: 
North Dakota: 
Oklahoma: 
Utah: 
Vermont: 
Wyoming: 

Greater than or equal to 5% and less than or equal to 6.5%: 
Alabama: 
Arkansas: 
Idaho: 
Louisiana: 
Maryland: 
Missouri: 
Montana: 
Nebraska: 
New York: 
Ohio: 
South Carolina:
Texas: 
Washington: 

Greater than or equal to 6.5% and less than 9.0%: 
California: 
Connecticut: 
Delaware: 
Florida: 
Georgia: 
Illinois: 
Kansas: 
Maine: 
Mississippi: 
New Jersey: 
Tennessee: 
West Virginia: 

Greater than 9.0%: 
Indiana: 
Iowa: 
Massachusetts: 
Michigan: 
Minnesota: 
North Carolina: 
Oregon: 
Pennsylvania: 
Rhode Island: 
South Dakota: 
Virginia: 
Wisconsin: 

Sources: GAO analysis of CMS data; Map Resources (map). 

[End of figure] 

Figure 6: Mean Incentive Payments from the 2009 Electronic Prescribing 
Program, by State: 

[Refer to PDF for image] 

Less than $2,500: 
Alaska: 
Colorado: 
Connecticut: 
Idaho: 
Massachusetts: 
Minnesota: 
Montana: 
New Hampshire:
North Dakota: 
Pennsylvania: 
Rhode Island: 
South Dakota: 
Vermont: 
Wisconsin: 

Greater than or equal to $2,500 to less than $3,200: 
California: 
Maine: 
Michigan: 
North Carolina: 
Oklahoma: 
Tennessee: 
Utah: 
Virginia: 
Washington: 
West Virginia: 
Wyoming: 

Greater than or equal to $3,200 to less than $4,000: 
Arizona: 
Hawaii: 
Illinois: 
Indiana: 
Iowa: 
Kansas: 
Maryland: 
Missouri: 
Nebraska: 
Nevada: 
New Mexico: 
New York: 
Ohio: 
Texas: 

Greater than $4,000: 
Alabama: 
Arkansas: 
Delaware: 
Florida: 
Georgia: 
Kentucky: 
Louisiana: 
Mississippi: 
New Jersey: 
South Carolina: 

Sources: GAO analysis of CMS data; Map Resources (map). 

[End of figure] 

About 87,500 Medicare providers--approximately 15 percent of Medicare 
providers who had at least one applicable visit during 2009-- 
participated in the program in 2009 by reporting the electronic 
prescribing reporting codes to CMS. However, about 40,000 of those 
participating providers--approximately 7 percent of Medicare providers 
who had at least one applicable visit during 2009--did not receive 
incentive payments because they did not meet or exceed both components 
of the reporting requirement.[Footnote 59] (See figure 7.) 
Specifically, these providers (a) submitted the electronic prescribing 
reporting codes less than 50 percent of the time that they had an 
applicable visit, (b) had less than 10 percent of their total allowed 
Medicare Part B charges for the year from the services designated as 
applicable visits, or (c) both (a) and (b) occurred. The vast majority 
of the about 40,000 Medicare providers that participated in the 
program but did not receive incentive payments submitted the 
electronic prescribing codes less than 50 percent of the time they had 
an applicable visit. 

Figure 7: Electronic Prescribing Program, 2009: 

[Refer to PDF for image: pie-chart] 

Did not participate (about 510,000 providers): 85%; 
Participated-—received incentive (about 47,500 providers): 8%; 
Participated—-did not receive incentive (about 40,000 providers): 7%. 

Source: GAO analysis of CMS data. 

[End of figure] 

While the Requirements in the EHR and Electronic Prescribing Programs 
Are Similar in Some Cases, Aspects of These Requirements Are Not 
Consistent: 

We compared the electronic prescribing-related technology and 
reporting requirements in the EHR Program with the requirements in the 
Electronic Prescribing Program. The EHR Program provides incentives 
from 2011 to 2016 and introduces penalties beginning in 2015, while 
the Electronic Prescribing Program provides incentives from 2009 to 
2013 and introduces penalties beginning in 2012. In comparing the 
programs' requirements, we found some similarities but also areas 
where the requirements of the programs are not consistent. 

Technology requirement. Both the EHR and Electronic Prescribing 
Programs require eligible providers to adopt and use technology that 
meets certain requirements. The EHR Program requires providers to 
adopt certified EHR technology and the Electronic Prescribing Program 
requires providers to adopt qualified electronic prescribing systems. 
(For more details, see figure 8.) 

Figure 8: Technology Requirement for the EHR and Electronic 
Prescribing Programs, 2011: 

[Refer to PDF for image: table] 

EHR Program[A]: 
Providers must adopt and use systems that meet CMS’s definition of a 
qualified electronic prescribing system. A qualified electronic 
prescribing system must be able to perform the following technical 
capabilities: (1) generate a complete medication list; (2) generate 
and transmit prescriptions electronically, and conduct alerts; (3) 
provide information on formulary or tiered formulary medications, 
patient eligibility, and authorization requirements; and (4) provide 
information on lower-cost, therapeutically appropriate alternatives 
(if any).[B] 

Electronic Prescribing Program: 
Providers must adopt and use certified EHR technology, which is 
technology that meets certain certification criteria established by HHS’
s ONC. The certification criteria describe the minimum related 
standards and implementation specifications. Each reporting 
requirement, including those related to electronic prescribing, is 
linked to certification criteria. 

Notes: Where applicable, systems used for the EHR and Electronic 
Prescribing Programs will be consistent with CMS's Part D electronic 
prescribing standards. For example, systems for both programs use the 
National Council for Prescription Drug Programs' standard on 
prescription transmission. 

[A] In addition to 2011, this requirement also applies for the 
duration of the first stage of the EHR Program, which remains in 
effect from 2012 to 2014. 

[B] According to CMS, the ability of an electronic prescribing system 
to receive tiered formulary information would suffice for the 
requirement to provide information on lower-cost alternatives in 2011 
or until this function is more widely available in the marketplace. 
See 75 Fed. Reg. 73556. 

[End of figure] 

Certified EHR systems and qualified electronic prescribing systems 
must be able to perform similar electronic prescribing-related 
activities. For example, both types of systems must be able to 
generate and transmit prescriptions electronically, check for 
potential drug and allergy interactions, and provide formulary 
information. 

The technology that providers must adopt and use for the EHR Program 
must pass a certification process, which is used to designate a 
technology as having met the program's technology requirements. For 
the EHR Program, HHS's ONC, through the work of several advisory 
committees, established a set of standards and specifications for EHR 
technology and then created a program that will certify EHR technology 
for use in the EHR Program based upon those standards and 
specifications.[Footnote 60] According to ONC's Web site, the 
certification process will ensure that the EHR technology that 
providers adopt and use has the technological capabilities necessary 
for providers to obtain incentive payments or avoid penalties from the 
EHR Program.[Footnote 61],[Footnote 62] Further, the agency notes that 
certifying EHR technology to these standards enhances the 
interoperability of health information technology--that is, the 
ability of different systems or components to exchange information and 
to use the information that has been exchanged.[Footnote 63] EHRs that 
conform to interoperability standards allow health information to be 
created, managed, and consulted by authorized health care providers 
across more than one health care organization, thus providing patients 
and their caregivers the necessary information required for optimal 
care. 

The EHR Program's certification process is designed to produce a list 
of certified EHR systems and certified EHR modules, which ONC has made 
available to the public on its Web site. Accordingly, this information 
should allow providers to identify and adopt systems that meet the EHR 
Program's technological requirements.[Footnote 64] A module is a 
component of an EHR system that meets at least one of the 
certification criteria established by ONC.[Footnote 65] Individual EHR 
modules can be certified and integrated with other certified EHR 
modules to form a complete, certified EHR system. At the time of our 
review, technologies certified for use in the EHR Program--that is, 
complete EHR systems or combinations of modules that collectively can 
perform the capabilities that constitute a qualified electronic 
prescribing system--appeared to also meet the Electronic Prescribing 
Program's technological requirements.[Footnote 66] Although according 
to ONC officials, certified EHR technology is not required to provide 
information on lower-cost alternatives--which is a component of the 
Electronic Prescribing Program's technology requirement--CMS has 
indicated that an electronic prescribing system that does not conform 
to that component of the Electronic Prescribing Program's technology 
requirement would still meet the definition of a qualified system in 
2011 and until this function is more widely available in the 
marketplace.[Footnote 67] 

Although providers seeking incentive payments or trying to avoid 
penalties from the Electronic Prescribing Program must adopt and use 
qualified electronic prescribing systems, according to a CMS official 
the Electronic Prescribing Program does not have a process like the 
EHR Program's to identify and certify which electronic prescribing 
systems meet the requirements of a qualified system.[Footnote 68] As a 
result, providers may not be certain which systems meet the program's 
technological requirement.[Footnote 69] 

Reporting requirements. Both the EHR Program and Electronic 
Prescribing Program require eligible providers to report certain 
information about their electronic prescribing activities to CMS in 
order to receive incentive payments, which began in 2009 for the 
Electronic Prescribing Program and began in 2011 for the EHR Program. 
(See figure 9 for a summary of the two programs' electronic 
prescribing-related reporting requirements.) However, we also found 
that the electronic prescribing-related reporting requirements in the 
EHR Program are more rigorous. Providers seeking incentive payments 
from the EHR Program have at least five reporting requirements related 
to electronic prescribing,[Footnote 70] while providers in the 
Electronic Prescribing Program have only one reporting requirement. 
[Footnote 71] Moreover, the EHR Program requires providers to report 
more-detailed information--namely, information on their use of various 
electronic prescribing-related technological capabilities--a 
requirement that should increase their use of these capabilities. 
[Footnote 72] Additionally, while CMS has established reporting 
requirements providers must meet in order to avoid the penalties under 
the Electronic Prescribing Program that begin in 2012, CMS has not yet 
identified what providers must report in order to avoid penalties 
under the EHR Program, but plans to do so in future rulemakings. 

Figure 9: Electronic Prescribing-Related Reporting Requirements for 
the EHR and Electronic Prescribing Programs, 2011: 

[Refer to PDF for image: table] 

Electronic Prescribing-–Related Reporting Requirements to Receive an 
Incentive Payment: 

EHR Program[A]: Generate and transmit more than 40 percent of 
permissible prescriptions electronically;[B,C] [Bolded] 
Electronic Prescribing Program: Individual providers must report the 
electronic prescribing code for at least 25 applicable visits. 
Submitting the code indicates the provider electronically transmitted 
at least one prescription during a visit using a qualified electronic 
prescribing system. Providers that choose to report to CMS as part of 
a group practice must report the electronic prescribing code for at 
least 75 to 2,500 applicable visits, depending upon the size of the 
group practice.[D] For individuals or groups, 10 percent of their 
total Part B charges must be designated as applicable patient visits. 

EHR Program[A]: Enter medication order into Computerized Physician 
Order Entry system for more than 30 percent of patients with at least 
one medication in their medication lists;[B,E] [Bolded] 
Electronic Prescribing Program: Not a reporting requirement. 

EHR Program[A]: Enter medication lists or indicate no current 
prescriptions for more than 80 percent of patients; [Bolded] 
Electronic Prescribing Program: Not a reporting requirement.[F] 

EHR Program[A]: Enter medication allergy lists or indicate no known 
medication allergies for more than 80 percent of patients; [Bolded] 
Electronic Prescribing Program: Not a reporting requirement. 

EHR Program[A]: Enable the EHR system’s ability to check a 
prescription for potential drug–drug and drug–allergy interactions; 
[Bolded] 
Electronic Prescribing Program: Not a reporting requirement.[F] 

EHR Program[A]: Perform medication reconciliation for more than 50 
percent of all transitions of care;[G,H] 
Electronic Prescribing Program: Not a reporting requirement. 

EHR Program[A]: Enable the EHR system’s ability to check a 
prescription against a formulary and maintain access to at least one 
internal or external drug formulary for the entire EHR reporting 
period;[B] 
Electronic Prescribing Program: Not a reporting requirement.[F] 

Electronic Prescribing–Related Reporting Requirements to Avoid a 
Penalty: 

EHR Program[A]: CMS has yet not determined what providers will be 
required to report in order to avoid penalties, which begin in 2015; 
Electronic Prescribing Program: To avoid the penalty in 2012: 
Individual providers must report the electronic prescribing code for 
at least 10 applicable visits between January 1, 2011, and June 30, 
2011, using a qualified electronic prescribing system.[I] Providers 
that choose to report to CMS as part of a group practice must report 
the electronic prescribing code for at least 75 to 2,500 applicable 
visits between January 1, 2011, and June 30, 2011, depending upon the 
size of the group practice.[D] 

Source: GAO analysis of CMS data. 

Notes: For the EHR Program, the five bolded requirements above are 
mandatory and the two nonbolded requirements are additional 
requirements that providers may choose to report. Providers wanting to 
obtain incentive payments for the EHR Program will have to meet a 
total of 20 reporting requirements (15 mandatory and an additional 5 
that they choose from a menu of 10 additional requirements). See 
appendix V for a complete list of the reporting requirements. Certain 
reporting requirements may not apply to all eligible providers; in 
such cases, eligible providers would report to CMS which reporting 
requirements did not apply to their practices. For example, 
chiropractors--who do not have prescribing authority--would report to 
CMS that the reporting requirements listed above did not apply to 
their practices. 

[A] In addition to 2011, these requirements also apply for the 
duration of the first stage of the EHR Program, which remains in 
effect from 2012 to 2014. 

[B] Providers who write fewer than 100 prescriptions during the 
reporting period would be exempt from this reporting requirement. 

[C] A prescription is considered permissible if it is not subject to 
Department of Justice restrictions on the electronic prescription of 
narcotics or other controlled substances. 

[D] Group practices of 2-10 providers must report the electronic 
prescribing code for at least 75 applicable visits; 11-25 providers 
must report the code for at least 225 applicable visits; 26-50 
providers must report the code for at least 475 applicable visits; 51-
100 providers must report the code for at least 925 applicable visits; 
101-199 providers must report the code for at least 1,875 applicable 
visits; and 200 or more providers must report the code for at least 
2,500 applicable visits. 

[E] Computerized physician order entry refers to systems used for 
medication-ordering designed to help ensure that medication orders are 
standardized, legible, and complete. 

[F] When providers report the electronic prescribing code, they are 
attesting that they used a qualified electronic prescribing system, 
which has the technological capability that corresponds to this EHR 
Program reporting requirement. 

[G] Medication reconciliation is the electronic comparison of two or 
more medication lists in instances such as when a patient's provider 
or setting of care changes. 

[H] Providers who do not receive a transition of care during the 
reporting period would be exempt from this reporting requirement. 

[I] Certain individual providers may be exempt from receiving a 
penalty under the Electronic Prescribing Program. For example, a 
provider with fewer than 100 applicable patient visits between January 
1, 2011, and June 30, 2011, would be exempt from receiving a penalty. 

[End of figure] 

We also found that the two programs' reporting requirements are not 
consistent because they make certain Medicare providers subject to 
both programs' reporting requirements during the same year. 
Specifically, physicians--the largest population among each program's 
eligible providers--may choose to participate in the EHR Program in 
2011 because the potential incentive payment will likely be higher 
under that program than under the Electronic Prescribing Program in 
2011.[Footnote 73] However, to avoid the penalty assessed by the 
Electronic Prescribing Program in 2012, CMS will require physicians to 
meet the Electronic Prescribing Program's reporting requirement in 
2011,[Footnote 74] even if they elect to participate in the EHR 
Program in 2011.[Footnote 75] Public comments on the agency's proposed 
requirements for the 2011 Electronic Prescribing Program included the 
concern that providers are burdened by having to submit electronic 
prescribing data more than once. In response, CMS stated that it will 
study possible methods of aligning the two programs and will include 
this information in the integration plan it is already required to 
develop by January 1, 2012, to integrate the reporting requirements in 
the EHR Program and PQRS, CMS's quality measures program.[Footnote 76] 
However, if CMS adheres to this schedule, the agency will not be able 
to remove the reporting burden placed on physicians subject to 
penalties from the Electronic Prescribing Program in 2013, given that 
the requirements for avoiding penalties in 2013 would likely be 
proposed in July 2011 and finalized in November 2011. If CMS includes 
possible methods of aligning the two programs in the integration plan, 
any action to propose and finalize requirements will take place 
sometime after January 1, 2012, well beyond the date for making 
changes to the program in 2013. In technical comments provided on a 
draft of this report, HHS noted that it plans to include possible 
methods of aligning the two programs for the 2012 program year (and 
possibly for the 2013 program year) in rulemaking during 2011. 
[Footnote 77] 

Both the EHR Program and Electronic Prescribing Program require 
providers seeking incentive payments to attest that they have met the 
programs' reporting requirements. In the EHR Program, providers will 
submit the results of their performance on each of the reporting 
requirements once per program year, while providers in the Electronic 
Prescribing Program attest that they adopted and used a qualified 
electronic prescribing system by reporting the electronic prescribing 
code to CMS. At least with reference to the EHR Program, CMS has 
acknowledged that attestation may create a potential for fraud and 
abuse and noted that the agency is developing an audit strategy to 
address this risk.[Footnote 78] CMS officials from the Office of E- 
Health Standards and Services told us they plan to make guidance on 
this strategy available by May 2011. In the case of the Electronic 
Prescribing Program, an official from CMS's Office of Clinical 
Standards and Quality, which administers that program, told us that 
the agency did not audit electronic prescribing codes submitted by 
providers for 2009 and does not have plans to develop an audit 
strategy for the program. However, this official did tell us that CMS 
reserves the right to audit any program participant.[Footnote 79] 

Conclusions: 

Health information technology, such as electronic prescribing, has the 
potential to improve the quality of care received by patients and also 
reduce costs for the health care system. To help encourage the 
adoption of such technologies among Medicare providers, Congress first 
established the Electronic Prescribing Program and then the EHR 
Program, both of which provide incentive payments to eligible 
providers that adopt and use the appropriate health information 
technologies and impose penalties on those eligible providers that 
fail to do so. 

Despite both programs having a goal to expand the adoption and use of 
health information technologies by health providers, and in 
particular, physicians--the largest and only group of providers 
eligible to earn incentive payments in both programs--we found 
inconsistencies in the requirements. We believe these inconsistencies 
may limit the programs' effectiveness in encouraging the use of health 
information technologies. First, we found that because the Electronic 
Prescribing Program lacks a certification process like that 
established for the EHR Program, physicians and other health care 
providers who want to obtain incentive payments or avoid penalties 
from the former program have no assurance that the systems they invest 
in will meet that program's technology requirements. In contrast, 
physicians who invest in certified EHR systems can be assured that in 
doing so they would meet the current requirements of both programs. In 
addition, physicians that invest in certified EHR modules integrated 
together to perform the electronic prescribing-related capabilities 
could also be assured that they meet the current requirements of the 
Electronic Prescribing Program and that the adopted technology could 
later be integrated with other certified modules to form a complete, 
certified EHR system. This inconsistency between the programs has the 
potential to create uncertainty among physicians as to what technology 
they should adopt, because although the Electronic Prescribing Program 
ends after 2014, the EHR Program continues; encouraging physicians to 
adopt certified electronic prescribing technology now may also help 
facilitate their later transition between the programs. Nonphysician 
health care providers who are not eligible to earn incentive payments 
from the EHR Program could adopt certified technology and in so doing 
could have assurance that the electronic prescribing technology they 
invest in meets the Electronic Prescribing Program's technology 
requirements. Second, we also found that the two programs have 
established separate reporting requirements related to electronic 
prescribing, requiring some physicians who elect to report to the EHR 
Program to report to both programs in 2011 and potentially requiring 
physicians to report to both programs through 2014, when penalties for 
the Electronic Prescribing Program end. CMS recognizes that this 
duplication places additional burden on physicians, and we believe 
this duplication could affect the decision of physicians to adopt and 
use health information technology. However, CMS is still in the 
process of studying possible ways to address this duplication, and if 
the agency wants to eliminate the burden for providers in 2012, it 
would need to do so during its 2011 rulemaking. In addition, CMS has 
not been consistent in the steps it has taken to ensure the 
appropriate use of these programs' resources. Namely, CMS plans to 
establish an audit program for the EHR Program--under which the 
maximum incentive payment for a provider will generally not exceed 
$18,000 per year--to address potential fraud and abuse that might 
arise from the use of self-attestations, but CMS does not have plans 
to develop a similar approach in the Electronic Prescribing Program, 
under which CMS paid providers up to approximately $67,500 for 2009. 

The Electronic Prescribing Program began before the EHR Program, so 
CMS has already had the opportunity to encounter and learn from 
challenges in implementation. For example, in the first year of the 
Electronic Prescribing Program, only about 8 percent of providers 
received incentive payments, and CMS changed some of the program's 
requirements in the second year to encourage greater adoption and use 
of electronic prescribing technology. For the EHR Program, it is too 
soon to know how many providers will adopt EHR systems. However, given 
that the electronic prescribing-related reporting requirements in the 
EHR Program are more rigorous than the reporting requirement in the 
Electronic Prescribing Program, CMS may find that it needs to modify 
the EHR Program requirements to better encourage the adoption and use 
of EHR systems. Because implementation of the Electronic Prescribing 
Program preceded the EHR Program, CMS has an opportunity to use the 
experiences gained in implementing the Electronic Prescribing Program 
to inform its implementation of the EHR Program in order to determine 
how to best encourage the adoption and use of health information 
technology among Medicare providers. One approach could be to 
incorporate these experiences into the integration plan the agency is 
already required to develop by January 1, 2012, to integrate the 
reporting requirements in the EHR Program and PQRS. 

Recommendations for Executive Action: 

To help improve the effectiveness of the Electronic Prescribing and 
EHR Programs to encourage the adoption of health information 
technologies among Medicare providers, the Administrator of CMS should 
take the following three actions: 

* Encourage physicians and other health care providers in the 
Electronic Prescribing Program to adopt certified electronic 
prescribing technology. 

* Expedite efforts to remove the overlap in reporting requirements for 
physicians who may be eligible for incentive payments or subject to 
penalties under both the Electronic Prescribing and EHR Programs by, 
for example, aligning the reporting requirements so that successfully 
qualifying for incentive payments or for avoiding penalties under the 
EHR Program would likewise result in meeting the requirements for the 
Electronic Prescribing Program. 

* Identify factors that helped or hindered implementation of the 
Electronic Prescribing Program to help support the ongoing 
implementation of the EHR Program. CMS could include consideration of 
such factors in the integration plan that the agency is required to 
develop by January 1, 2012. 

To help ensure that Electronic Prescribing Program resources are used 
appropriately, the Administrator of CMS should develop a risk-based 
strategy to audit a sample of providers who received incentive 
payments from the Electronic Prescribing Program to help ensure that 
providers who receive incentive payments meet that program's 
requirements. A risk-based strategy could, for example, focus on those 
providers who received larger incentive payments. 

Agency and External Party Comments and Our Evaluation: 

We obtained written comments on our draft report from HHS on behalf of 
CMS, which are reprinted in appendix VI. CMS agreed in full with two 
recommendations, agreed in principle with one recommendation, and 
disagreed with a fourth recommendation. 

CMS disagreed with our first recommendation that the agency direct 
providers in the Electronic Prescribing Program to use technology 
certified as an EHR system or module(s). While CMS said that it 
concurred with the notion that eligible providers should be able to 
use certified EHR systems for the Electronic Prescribing Program, it 
did not agree that it should direct eligible providers to use 
prescribing technology that has been certified as an EHR system. CMS 
said that doing so could result in Electronic Prescribing Program 
participants having to replace their qualified electronic prescribing 
systems with systems certified under the EHR Program. We do not 
recommend that CMS direct those providers who are already 
participating in the Electronic Prescribing Program to replace their 
current systems with certified systems. On the contrary, the intent of 
our recommendation is to have CMS encourage providers in the 
Electronic Prescribing Program who have not yet adopted electronic 
prescribing systems, or who plan on upgrading their existing systems, 
to choose systems that have already been certified through the EHR 
Program's certification process. We continue to assert our 
recommendation because, as we noted in our draft report, this 
certification process identifies a list of available systems that meet 
the certification requirements and provides assurance that the 
technology physicians and other health care providers adopt would meet 
the technology requirements of the Electronic Prescribing Program. 
Additionally, the physicians who later participate in the EHR Program 
could be assured that the technology also meets the requirements in 
the EHR Program. In our draft report, we noted that there is no 
comparable process in the Electronic Prescribing Program, and as a 
result, providers have no assurance that the systems they invest in 
for the EHR Program will meet that program's technology requirements. 
Given that the Electronic Prescribing Program ends after 2014 while 
the EHR Program will continue, encouraging providers to adopt 
certified electronic prescribing technology now may also help 
facilitate physicians' transition between the programs. We have 
clarified the recommendation to state that CMS should encourage 
physicians and other health care providers in the Electronic 
Prescribing Program to adopt certified electronic prescribing 
technology. 

CMS agreed with our second recommendation that it expedite efforts to 
remove the overlap in reporting requirements for physicians eligible 
for both programs, and noted that it plans to address this overlap in 
rulemaking during 2011, where applicable. We support CMS's efforts to 
expeditiously remove the overlap in the reporting requirements as we 
recommended. 

CMS agreed with our third recommendation that it would be helpful for 
the agency to identify factors that helped or hindered implementation 
of the Electronic Prescribing Program to help support the ongoing 
implementation of the EHR Program. While CMS identified factors that 
may be affecting implementation of electronic prescribing, other 
factors that may have broader applicability to the implementation of 
the EHR Program could include the effect of penalties on technology 
adoption, measuring compliance with program requirements, and 
validating self-reported attestations. 

CMS agreed in principle with our fourth recommendation that CMS 
develop a risk-based strategy to audit a sample of providers who 
received incentive payments from the Electronic Prescribing Program. 
In response CMS said that it agrees that an audit of a sample of 
providers may be needed, however, it disagreed that such a strategy 
should necessarily focus on eligible providers who received large 
incentive payments, noting that such an audit process, if implemented, 
could select providers at random. As we recommended, we believe that 
an audit strategy should be implemented for this program. We 
recommended a risk-based audit strategy because although many 
providers received modest incentive payments in 2009, some providers 
received payments at least three times as high as the maximum annual 
incentive payment in the EHR Program. However, if implemented by CMS, 
a random audit would be consistent with the intent of our 
recommendation. CMS also noted that because it is considering using 
Part D data in the future to determine which providers should receive 
incentive payments for this program, use of these data could also 
alleviate the need for an audit. However, as we noted in our draft 
report, CMS officials raised several concerns--concerns echoed in its 
comments on our draft report--about the reliability of Part D data to 
determine which providers receive incentive payments. As we reported, 
CMS officials told us that these data reliability concerns should be 
resolved before Part D data can be used to determine which providers 
should receive incentive payments for this program. 

HHS has also provided technical comments, which we incorporated as 
appropriate. We also provided excerpts of our report to the VA, Blue 
Cross Blue Shield of Massachusetts, CVS Caremark, the Florida Agency 
for Health Care Administration, and organizations that participated in 
the Southeastern Michigan ePrescribing Initiative, which provided 
technical comments that we incorporated as appropriate. 

We are sending copies of this report to the Secretary of HHS, the 
Administrator of CMS, and the National Coordinator for Health 
Information Technology in HHS and interested congressional committees. 
In addition, the report will be available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have questions about this report, please contact 
me at (202) 512-7114 or at kohnl@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix VII. 

Signed by: 

Linda T. Kohn: 
Director, Health Care: 

[End of section] 

Appendix I: List of Committees: 

The Honorable Max Baucus: 
Chairman: 
The Honorable Orrin G. Hatch: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable Tom Harkin: 
Chairman: 
The Honorable Michael B. Enzi: 
Ranking Member: 
Committee on Health, Education, Labor, & Pensions: 
United States Senate: 

The Honorable Fred Upton: 
Chairman: 
The Honorable Henry A. Waxman: 
Ranking Member: 
Committee on Energy and Commerce: 
House of Representatives: 

The Honorable Dave Camp: 
Chairman: 
The Honorable Sander M. Levin: 
Ranking Member: 
Committee on Ways and Means: 
House of Representatives: 

[End of section] 

Appendix II: Effect of Electronic Prescribing on Quality or Cost: 

This appendix addresses congressional interest in how others have 
measured whether or to what extent electronic prescribing improves 
quality or reduces cost.[Footnote 80] For example, the Medicare 
Improvements for Patients and Providers Act of 2008 (MIPPA) directed 
us to report on information related to reductions in avoidable medical 
errors and estimated savings to Medicare resulting from the use of 
electronic prescribing.[Footnote 81] To address these issues, we 
obtained information from organizations about research they conducted, 
funded, or participated in that measured the effects of electronic 
prescribing on quality, cost, or both. Specifically, we obtained 
information from the following organizations: Blue Cross Blue Shield 
of Massachusetts, CVS Caremark, the Florida Agency for Health Care 
Administration, and the Southeastern Michigan ePrescribing Initiative. 
[Footnote 82] In addition, we reviewed 29 published studies that 
measured the effects of electronic prescribing on quality, cost, or 
both.[Footnote 83] 

Our information collection, review of published studies, and summaries 
contained in this appendix focused on specific aspects of quality and 
cost that we believed were most similar to the policy goals underlying 
the development of the Electronic Prescribing Program and the 
Electronic Health Records (EHR) Program.[Footnote 84] 

* Quality. We included studies that reported findings related to 
beneficiary quality, such as reductions in avoidable medical errors. 

* Cost. We included studies that reported findings related to savings 
to health care payers, which are those parties generally responsible 
for paying claims for health care services, because we believed they 
would be the most applicable to determining the effects of electronic 
prescribing on costs for Medicare. We did not review studies that 
estimated potential savings for providers, such as savings associated 
with reductions in time spent writing prescriptions or resolving 
questions about prescriptions. 

The studies evaluated the effects of a variety of different types of 
electronic prescribing technology, such as stand-alone electronic 
prescribing systems and EHR systems that include electronic 
prescribing-related functions. According to the Healthcare Information 
and Management Systems Society (HIMSS), EHR systems also typically 
include information such as patient demographics, progress notes, 
problems, medications, vital signs, past medical history, 
immunizations, laboratory data, and radiology reports. Additionally, 
computerized physician order entry (CPOE) systems (also referred to as 
computerized provider order entry systems or computerized prescriber 
order entry systems) allow for electronic ordering of medications and 
may include other functions, such as ordering laboratory procedures 
and referrals. Hospitals may employ CPOE systems as part of a strategy 
to reduce medication errors. Some organizations and published studies 
evaluated the effects of electronic prescribing systems that had 
clinical decision support (CDS) capabilities, which can include checks 
for allergies, drug-drug interactions, overly high doses, clinical 
conditions, and other patient-specific dose checking, and can provide 
access to information on patient medical histories, pharmacy 
eligibility, and formulary and benefits. It is important to note that 
the electronic prescribing systems evaluated by the organizations we 
obtained information from and published studies we reviewed may have 
had technical capabilities that differ from the technological 
requirements in the Electronic Prescribing Program or the EHR Program. 

Methodology: 

The studies utilized a variety of different methodologies, including 
the following: (1) pre-post methodologies, which compare dimensions of 
quality or cost before and after the implementation of electronic 
prescribing systems or CPOE systems; (2) comparison methodologies, 
which are used to compare dimensions of quality, cost, or both between 
a control group (i.e., one that does not electronically prescribe) and 
an intervention group (i.e., one that does electronically prescribe); 
and (3) cost simulations and cost-benefit analyses that projected the 
costs and savings of implementing electronic prescribing systems. 

How Electronic Prescribing Was Determined: 

Some studies identified compared a population of providers that 
electronically prescribed to a population that did not (e.g., 
handwrote prescriptions). For example, some studies identified a 
population of providers who had access to electronic prescribing 
systems and compared them to a population of other providers who did 
not have access to electronic prescribing systems, while other studies 
identified prescriptions before CPOE implementation and compared those 
prescriptions to prescriptions transmitted after CPOE implementation. 
Other studies only looked at populations of providers known to be 
electronic prescribers. Other studies were designed to evaluate the 
effect of advanced features of the electronic prescribing system. For 
example, one study by Steel et al. was designed to compare medication 
ordering behavior when no alert was triggered by the CPOE system to 
ordering behavior after alerts were triggered. 

Outcomes Measured: 

The organizations we interviewed and published studies we reviewed 
examined a variety of different outcomes in order to evaluate the 
effect on quality, cost, or both. Examples of the outcomes measured to 
evaluate the effect of electronic prescribing on health care quality 
include the following: 

* medication order changes resulting from information provided by the 
electronic prescribing system, such as alerts for potentially 
inappropriate medications or formulary information, or changes 
resulting from problems with the quality of the prescription such as 
errors identified by the electronic prescribing system related to 
dosage, directions, or illegibility; 

* changes in potential or actual adverse drug events (ADE); and: 

* provider satisfaction that the electronic prescribing system was 
improving safety. 

Examples of the outcomes measured to evaluate the effect of electronic 
prescribing on cost include the following: 

* drug costs or other outcomes that have cost implications, such as 
formulary compliance or generic utilization; and: 

* follow-up health care costs resulting from reductions in adverse 
drug events. 

Reported Findings: 

In terms of health care quality, some studies found differences in 
medication error rates when electronic prescribing was used. For 
example, a study conducted by Weingart et al. and funded by Blue Cross 
Blue Shield of Massachusetts estimated that medication safety alerts 
prevented an estimated 402 ADEs (49 serious or life threatening, 125 
significant, and 228 minor) and that alerts that resulted in 
physicians canceling or changing the medication order may have 
prevented deaths in 3 cases, permanent disability in 14 cases, and 
temporary disability in 31 cases. Another study by Devine et al. 
reported that rates of errors in prescriptions declined from 18.2 
percent before to 8.2 percent after implementation of a CPOE system. 
However, some studies found no significant differences in medication 
error rates before and after the implementation of electronic 
prescribing systems. 

Some of the evaluations that focused on prescription drug costs showed 
savings when electronic prescribing systems were used. For example, a 
cost-benefit analysis conducted by Byrne et al. estimated that the use 
of Veterans Health Information Systems and Technology Architecture 
(VistA), which includes electronic prescribing and CDS capabilities of 
the Department of Veterans Affairs (VA) health system electronic 
health records, contributed to a cumulative $4.64 billion in value due 
to the prevention of unnecessary hospitalizations and outpatient 
visits resulting from prevented ADEs. In this study, the total net 
value of the VA's investments in the VistA components modeled was 
estimated to exceed $3.09 billion. A study by McMullin et al. of an 
electronic prescribing system that provided patient formulary 
information shifted prescriber behavior from selecting drugs from 
eight high-cost therapeutic groups to less-expensive alternatives. 
However, a study by Ross et al. found no significant difference in 
formulary compliance between electronic prescribers (83.2 percent) and 
paper prescribers (82.8 percent). 

Of the studies we reviewed in which the electronic prescribing systems 
were reported to have CDS capabilities--such as drug-drug, drug-
allergy alerts, or drug-formulary checks--most reported health care 
quality or cost effects. For example, a study by DesRoches et al. 
reported that providers who adopted EHR with electronic prescribing 
decision support capabilities averted potentially dangerous drug-drug 
interactions. One study by Galanter et al. found that the likelihood 
of contraindicated drugs being administered to patients of inadequate 
kidney function decreased by 42 percent after electronic prescribing 
CDS alerts were implemented. Ko et al. surveyed providers and found 
that the majority viewed drug-drug interaction alerts as increasing 
their potential to more safely prescribe medications. Another study by 
Kaushal et al. attributes the implementation of a CPOE with CDS as 
leading to an estimated $28.5 million in savings--$12.9 million from 
decreased adverse drug events and $6 million from decreased drug 
costs--however, the study also estimated that the cost to develop, 
implement, and operate the CPOE system was $11.8 million. 

Table 1: Summaries of Evaluations Obtained from Organizations: 

Blue Cross Blue Shield of Massachusetts: 

Beginning in 2003, Blue Cross Blue Shield of Massachusetts contracted 
with software vendors to provide electronic prescribing software, 
which included CDS, free of charge to high-volume prescribers in their 
provider network. Blue Cross Blue Shield of Massachusetts continues to 
sponsor a limited number of electronic prescribing software licenses 
free of charge. As of September 2010, Blue Cross Blue Shield of 
Massachusetts estimated that 60 percent of its network physicians were 
electronically prescribing. 

Study #1: Prescribing Patterns: 

Methodology; A pre-post study comparing 1,932 Blue Cross Blue Shield 
of Massachusetts's providers that were using an electronic prescribing 
device to the providers in the network that were not electronically 
prescribing (control group). The preintervention period was calendar 
year 2003 and the postintervention period was 2006. 

How electronic prescribing was determined: Whether the prescriber used 
an electronic prescribing device, as determined from data obtained 
from Blue Cross Blue Shield of Massachusetts's pharmacy benefits 
manager. 

Outcome(s) measured: (1) Prescribing patterns by drug tier. (2) 
Savings in drug costs as a result of different prescribing patterns. 

Reported findings: (1) Prescribers who used an electronic prescribing 
device prescribed more generic and on-formulary prescriptions. (2) 
Prescribers saved Blue Cross Blue Shield of Massachusetts 5 percent on 
drug costs relative to those prescribers that did not use an 
electronic prescribing device. 

Other issues: Blue Cross Blue Shield of Massachusetts noted that some 
of the individuals in the control group may have been electronically 
prescribing but they assumed in the study that they were not because 
of the absence of data. 

Study #2: Fischer, M.A., C. Vogeli, M. Stedman, T. Ferris, M.A. 
Brookhart, and J.S. Weissman. "Effect of Electronic Prescribing With 
Formulary Decision Support on Medication Use and Cost." Archives of 
Internal Medicine, vol. 168, no. 22. (2008): 2433-39. 

Methodology: Blue Cross Blue Shield of Massachusetts provided pharmacy 
claims data used by the researchers in a pre-post study of the 
implementation of electronic prescribing software with formulary 
decision support. The study consisted of an intervention group of 
1,198 prescribers who wrote at least one electronic prescription, and 
a control group of 34,453 prescribers who did not electronically 
prescribe. Claims data were collected for 18 months--6 months before 
the intervention (October 2003 through March 2004) and 12 months 
postintervention (April 2004 through March 2005)--and data on 
electronic prescriptions were collected in the 12 month 
postintervention period. 

How electronic prescribing was determined: Whether the prescriber 
wrote at least one electronic prescription, as captured by the 
electronic prescribing system. 

Outcome(s) measured: (1) The change in the proportion of prescriptions 
for three formulary tiers before and after electronic prescribing was 
implemented; and (2) the potential savings associated with this change. 

Reported findings: (1) Electronic prescribing led to a 3.3 percent 
increase in Tier 1 prescribing--that is, those medications with the 
lowest copayment. (2) On the basis of average costs, the study 
estimated that implementation of electronic prescribing software with 
formulary decision support could lead to a savings of $845,000 per 
100,000 patients. 

Study #3: Weingart, S.N., B. Simchowitz, H. Padolsky, T. Isaac, A.C. 
Seger, M. Massagli, R.B. Davis, and J.S. Weissman. "An Empirical Model 
to Estimate the Potential Impact of Medication Safety Alerts on 
Patient Safety, Health Care Utilization, and Cost in Ambulatory Care." 
Archives of Internal Medicine, vol. 169, no. 16. (2009): 1465-73. 

Methodology: Blue Cross Blue Shield of Massachusetts funded and 
provided some data for a study that estimated the quality improvement 
and savings associated with medication safety alerts. The study 
examined 1,833,254 prescriptions written using a commercial electronic 
prescribing system by 2,321 clinicians for 60,352 patients. During the 
study period (January through June 2006), 279,476 drug-drug 
interaction alerts were generated. For each drug-drug interaction, 
expert panelists examined whether it might result in an adverse drug 
event and the severity of that event. The study used published sources 
and payer data to estimate the costs to third-party payers associated 
with different types of health care services due to adverse drug 
events. 

How electronic prescribing was determined: All prescriptions were 
generated from the electronic prescribing system. The company that 
developed the electronic prescribing system provided researchers 
information on all drug-drug interactions generated and data on the 
prescribers' action on receiving the alert. 

Outcome(s) measured: (1) The likelihood and severity of the potential 
ADE that the alert prevented, and (2) cost savings estimated from 
reduced health care utilization. 

Reported findings: (1) The study estimated that medication safety 
alerts prevented an estimated 402 adverse drug events (49 serious or 
life threatening, 125 significant, and 228 minor). Alerts that 
physicians "accepted," meaning the physician either canceled the 
prescription or changed to an alternative medication, may have 
prevented deaths in 3 cases, permanent disability in 14 cases, and 
temporary disability in 31 cases. (2) Due to lower utilization of 
health care services the study estimated annual savings to be $402,619. 

[End of Blue Cross Blue Shield of Massachusetts] 

CVS Caremark: 
Beginning in 2000, CVS Caremark made electronic prescribing available 
through its proprietary iScribe system to interested providers by 
download from a Web site. In late 2004, CVS Caremark supported 
electronic prescribing by providing software, hardware, installation, 
training, and service to providers on behalf of health care payers. 

Study #1: Hutchins, D.S., M. Lewis, R. Velazquez, and J. Berger. "E-
Prescribing Reduces Beers Prescribing Among the Elderly." CVS 
Caremark, May 22, 2007. 

Methodology: A control group study of 383,855 prescription claims 
written for 14,557 persons over 65 years of age between April 2002 and 
June 2005 by over 3,700 providers, 70 of whom implemented an 
electronic prescribing tool that alerted them to the prescribing of 
"Beers List" medications to patients over 65 years of age. 

How electronic prescribing was determined: Whether the prescription 
was dispensed before or after a provider adopted the electronic 
prescribing tool. 

Outcome(s) measured: Whether use of the specific electronic 
prescribing tool had an effect on the prescribing of potentially 
inappropriate drugs from the Beers List to the elderly. 

Reported findings: Use of the specific electronic prescribing tool 
that provided alerts specific to Beers List medications can reduce 
prescribing of those medications among the elderly. 

Study #2: Hutchins, D.S., J.N. Liberman, J. Berger, S. Jan, M. M. 
Johnson. "The Impact of an Electronic Prescribing Solution on the 
Selection and Prescribing of Cost-Effective Therapeutic Options." CVS 
Caremark, 2009. 

Methodology: A pre-post control group study of over 9 million claims 
in seven drug classes prescribed by one of over 29,000 providers 
(about 250 of which used the electronic prescribing tool) that were 
filled between July 2002 and December 2005. 

How electronic prescribing was determined: Whether the provider used 
an electronic prescribing tool. 

Outcome(s) measured: Whether the use of an electronic prescribing 
system has an effect on prescribing low-cost generic and mail-
delivered drugs. 

Reported findings: Across multiple drug classes, study reported a link 
between use of electronic prescribing systems and a greater likelihood 
that generic drugs were prescribed and that they were dispensed 
through mail order, both of which likely lower overall costs. 

[End of CVS Caremark] 

The Florida Agency for Health Care Administration: 
The Florida Agency for Health Care Administration provided Medicaid 
providers, at no charge, access to a CDS tool called EMPOWERx, which 
allows for electronic prescribing and includes the following 
capabilities: provides comprehensive medication histories, alerts 
providers to drug-drug and drug-allergy interactions, and provides 
formulary information. 

Methodology: A comparison of the costs and savings for 1,000 Medicaid 
providers in the state in the EMPOWERx personal digital assistant 
program to the total population of Medicaid providers in the state. 

How electronic prescribing was determined: Whether or not the provider 
was in the EMPOWERx personal digital assistant program. 

Outcome(s) measured: (1) The average cost per patient for all 
prescriptions. (2) The estimated savings for prescriptions written by 
providers in the EMPOWERx personal digital assistant program, based on 
the difference between costs for providers in the two groups and the 
number of patients associated with the EMPOWERx personal digital 
assistant program providers. (3) The estimated savings for the 1,000 
Medicaid providers in the EMPOWERx personal digital assistant program 
based on information collected about alerts those providers received 
about drug interactions in response to a medication order, assumptions 
about avoidable hospitalizations, and assumptions about 
hospitalization costs. 

Reported findings: In the fourth quarter of 2009 (1) average costs per 
patient for all prescriptions were about $28 to $30 lower for the 
providers in the EMPOWERx personal digital assistant program; (2) the 
cost differences between the two groups represents estimated savings 
of approximately $5.5 million; and (3) by assuming that 5 percent of 
the 12,480 high-or very-high-severity drug interactions would have led 
to hospitalizations and that hospitalizations resulting from 
preventable drug interactions are associated with an average increased 
cost of $4,685 per incident, the study estimated that the state 
Medicaid program saved approximately $2.9 million. 

[End of The Florida Agency for Health Care Administration] 

Southeastern Michigan ePrescribing Initiative: 
The Southeastern Michigan ePrescribing Initiative, a collaborative 
effort of employers, health plans, pharmacy benefit managers, 
physician groups, and others, was launched in 2005 to speed the 
adoption of electronic prescribing. Some of the studies that resulted 
from this collaboration are summarized below. 

Study #1: An official with Medco described a study it conducted. Medco 
is a pharmacy benefit manager and member of the collaborative. 

Methodology: A comparison study of a group of 1,165 physicians who 
electronically prescribed to Medco's mail-order drug program and 1,000 
physicians that did not. Data were collected in the second quarter of 
2008. 

How electronic prescribing was determined: Providers were included in 
the electronic prescribing group if they had sent at least 20 
prescriptions electronically to Medco's mail-order drug program during 
the study time period. Providers were included in the nonelectronic 
prescribing group if they had not met this criterion and provided 
services in the same zip codes as the providers in the electronic 
prescribing group. 

Outcome(s) measured: The average cost per prescription per group for 
retail and mail order prescriptions, which was calculated by dividing 
total costs (identified through claims data) for each category and 
group by the number of prescriptions for each category and group. 

Reported findings: Providers in the electronic prescribing group saved 
an average of $2.11 per retail prescription and $7.44 per mail-order 
prescription compared to the group that did not electronically 
prescribe. 

Other issues: The Medco official noted that the findings were not 
tested for significance or subjected to other more-rigorous 
validations. It is possible that providers in the group that did not 
electronically prescribe were electronic prescribing, just not to 
Medco's mail order service drug program. In addition, while the 
providers in each group were from the same geographic service areas, 
Medco did not examine the types of patients served by the providers, 
so it is possible that the groups were serving different patient 
populations. 

Study #2: An official described a study conducted by HaldyMcIntosh, 
under the direction of the Southeastern Michigan ePrescribing 
Initiative project manager, Point-of-Care Partners. 

Methodology: A telephone survey of 500 providers participating in the 
collaborative that responded to the survey, conducted in the fourth 
quarter of 2007. 

How electronic prescribing was determined: Only providers that were 
electronically prescribing were surveyed. 

Outcome(s) measured: Providers' perceptions of the effect of 
electronic prescribing on quality. 

Reported findings: Nearly 70 percent of respondents highly agreed that 
electronic prescribing improves quality of care; almost 75 percent 
highly agreed that electronic prescribing improves patient safety; 
approximately 70 percent were very satisfied with the ease of 
identifying drug-related interactions; and more than 60 percent 
reported that they changed a prescription in response to a safety 
alert at least once. 

Study #3: An official with the Health Alliance Plan described a study 
conducted by Henry Ford Medical Group and the Health Alliance Plan 
that looked at generic utilization. 

Methodology: A comparison study conducted in 2005 of a group of 24 
physicians who electronically prescribed from eight practice sites and 
26 physicians from eight comparable practice sites that did not. 

How electronic prescribing was determined: Whether the practice site 
had converted to electronic prescribing. 

Outcome(s) measured: Rate of generic prescribing using pharmacy claims 
data and associated savings. 

Reported findings: Facilities with access to an electronic prescribing 
system had a 1.25 percent larger increase in their rate of generic 
prescribing compared with sites that did not have access to an 
electronic prescribing system. The study estimated that the health 
plan can save $800,000 per year for each 1 percentage point 
improvement in the rate of generic prescribing. 

Study #4: An official with the Health Alliance Plan described a study 
conducted by Henry Ford Medical Group and the Health Alliance Plan 
that looked at the savings associated with adverse drug events. 

Methodology: A cost estimate conducted in 2006 of the savings 
associated with decreases in ADEs. 

How electronic prescribing was determined: Whether a prescription was 
changed based on an alert from the electronic prescribing system, 
identified from internal data sources. 

Outcome(s) measured: Estimated savings in (1) avoidable 
hospitalizations and (2) avoidable emergency room admissions, due to 
the decrease in ADEs. 

Reported findings: (1) By assuming that 2 percent of hospitalizations 
are attributable to ADEs, that 33 percent of those are avoidable due 
to use of the electronic prescribing system, and that $7,000 is saved 
per avoidable hospitalization, the study estimated that $441,000 was 
saved in 2007. (2) By assuming that 1 percent of emergency room visits 
are attributable to ADEs, that 33 percent of those are avoidable due 
to use of the electronic prescribing system, and that $500 is saved 
per avoidable emergency room visit, the study estimated that $99,000 
was saved in 2007. 

Study #5: An official with the Health Alliance Plan described a study 
it conducted that identified patients taking contraindicated 
prescription drug combinations. 

Methodology: A file review of pharmacy and medical claims for about 
200,000 patients before implementation of electronic prescribing (in 
2004) and after implementation of electronic prescribing (in 2007) to 
identify patients that were prescribed contraindicated drug 
combinations. 

How electronic prescribing was determined: The study identified claims 
before and after implementation of electronic prescribing. 

Outcome(s) measured: The rate of patients taking contraindicated drug 
combinations. 

Reported findings: The study reported a 24 percent decrease in the 
incidence of patients with generally contraindicated medications and a 
48 percent decrease in patients taking medications contraindicated for 
pregnancy 1 year after the implementation of electronic prescribing. 

Study #6: An official with the Health Alliance Plan described a survey 
conducted by Henry Ford Medical Group and the Health Alliance Plan. 

Methodology: A 2006 survey about electronic prescribing attitudes. 
About 100 physicians in the Henry Ford Medical Group responded to the 
survey. 

How electronic prescribing was determined: Only physicians who were 
electronically prescribing were included in the survey. 

Outcome(s) measured: A variety of questions related to electronic 
prescribing attitudes, some of which focused on physician attitudes 
regarding the effect of electronic prescribing on safety. 

Reported findings: Various findings reported including the following 
percentages of respondents who "strongly agreed" or "somewhat agreed": 
84.6 percent of respondents reported that electronic prescribing has 
improved the practice of medicine in their clinics; 77.2 percent and 
74.8 percent reported that electronic prescribing improves the safety 
of the care and the quality of the care, respectively, provided to 
their patients; 66.7 percent reported that the drug-drug warnings were 
helpful, 80.5 percent reported that the drug-allergy warnings were 
helpful, and 68.3 percent reported that the formulary warnings were 
helpful. 

[End of Southeastern Michigan ePrescribing Initiative] 

Summaries of Evaluations Obtained from Literature Review: 

Byrne, C.M., L.M. Mercincavage, E.C. Pan, A.G. Vincent, D.S. Johnston, 
and B. Middleton. "The Value from Investments in Health Information 
Technology at the U.S. Department of Veterans Affairs." Health 
Affairs, vol. 29, no. 4 (2010): 629-638. 

Methodology: A comparison study of the VA health system and the 
private-sector health systems on information technology spending, 
adoption, and quality of care. The study also conducts a cost-benefit 
analysis to estimate the financial value of key components of the VA's 
VistA. 

How electronic prescribing was determined: Whether or not the health 
system surveyed had adopted health information technology and whether 
the health information technology system had certain capabilities as 
defined by six frameworks in relevant literature and internal VA and 
publicly available documents. 

Outcome(s) measured: (1) The information technology-related quality of 
care quantified using previously collected quality measures from the 
VA that could be compared to measures available for the private sector 
for 2004 to 2007. (2) Cost-benefit analysis that estimates the costs 
and effects of the core components of the VA VistA system from 2001 to 
2007. 

Reported findings: (1) The VA was found to have higher performance on 
preventive care process measures from 2004 to 2007 relative to the 
private sector. The VA averaged about 15 percentage points higher than 
the private sector on preventive care for patients with diabetes and 
17 percentage points higher for patients with diabetes who have well- 
controlled cholesterol. (2) The gross value of the investment in VistA 
applications was projected to be $7.16 billion. Of the gross value, 
the researchers estimated that cumulative reductions in unnecessary 
care attributable to VistA in preventing ADE-related hospitalizations 
and outpatient visits was valued at $4.64 billion, or 65 percent of 
the total estimated value. 

Other issues: The VA system electronically captures and reports 
allergies and adverse reactions, inpatient and outpatient medications, 
medication orders, and includes CDS such as clinical reminders and 
order checking. 

Cunningham, T.R., E.S. Geller, and S.W. Clarke. "Impact of Electronic 
Prescribing in a Hospital Setting: A Process-Focused Evaluation." 
International Journal of Medical Informatics, vol. 77, no. 8 (2008): 
546-554. 

Methodology: A pre-post study reviewing the medication orders of two 
different hospitals, a control hospital that did not implement a CPOE 
system and an intervention hospital that did at each of three 
different phases of the study--a 4-week baseline phase, a 3-week pilot 
phase, and 5-week post-CPOE implementation phase. At the control 
hospital, 247 handwritten orders were reviewed from the baseline 
phase, 279 handwritten orders from the pilot phase, and 453 
handwritten orders from the post-CPOE implementation phase. At the 
intervention hospital, 201 handwritten orders were reviewed from the 
baseline period, 283 electronically submitted orders were reviewed 
from the pilot phase, and 587 orders (276 handwritten and 311 
submitted electronically) were reviewed from the post-CPOE 
implementation phase. 

How electronic prescribing was determined: Whether or not the 
physicians' medication orders were handwritten or submitted 
electronically in the three different phases of the study, as 
identified from the files of previously processed medication orders 
stored in the pharmacy departments of each hospital. 

Outcome(s) measured: (1) Rates of compliance with hospital medication 
protocols (such as recording date, time, drug name, or dosage) by 
examining behavioral checklists used to collect information on each 
prescription written; and (2) time it took for a patient to receive 
antibiotics, as recorded in the hospital medication ordering database. 

Reported findings: (1) Medication orders submitted electronically at 
the intervention hospital were compliant with hospital medication 
protocols 79.9 percent of the time, compared to a 62.9 percent 
compliance rate for paper orders written at the same hospital, and a 
64.2 percent compliance rate for paper orders written at the control 
hospital. (2) At the intervention hospital, the average amount of time 
from the medication order until the first dose of antibiotics was 
administered was shorter for orders submitted through the CPOE system 
(185.0 minutes) than paper orders (326.2 minutes). 

Other issues: The CPOE had CDS but the specific features of the CDS 
system are not discussed. 

DesRoches, C.M., E.G. Campbell, S.R. Rao, K. Donelan, T.G. Ferris, A. 
Jha, R. Kaushal, D.E. Levy, S. Rosenbaum, A.E. Shields, and D. 
Blumenthal. "Electronic Health Records in Ambulatory Care--A National 
Survey of Physicians." New England Journal of Medicine, vol. 359, no. 
1 (2008): 50-60. 

Methodology: A survey of 2,758 physicians conducted between September 
2007 and March 2008. 

How electronic prescribing was determined: Whether or not physicians 
reported on the survey that they adopted an EHR system, including 
whether the EHR system was a "fully functional" or "basic" EHR. The 
study defined a "fully functional" EHR as one that allows physicians 
to record patients' clinical and demographic data, view and manage 
results of laboratory tests and imaging, manage order entry (including 
electronic prescriptions), and support clinical decisions (including 
warnings about drug interactions or contraindications). In the study, 
the principal differences between "fully functional" and "basic" EHRs 
were the absence of certain order-entry capabilities and CDS in a 
basic system. 

Outcome(s) measured: The survey asked respondent a variety of 
questions related to EHR adoption, including questions related to 
quality of care. 

Reported findings: Findings reported by the study included the 
following: of the respondents with fully functional EHR systems, 80 
percent reported averting a potentially dangerous drug allergic 
reaction and 71 percent of respondents reported averting a potentially 
dangerous drug interaction compared to 66 percent and 54 percent of 
respondents with basic EHR systems. 

DesRoches, C.M., E.G. Campbell, C. Vogeli, J. Xheng, S.R. Rao, A.E. 
Shields, K. Donelan, S. Rosenbaum, S.J. Bristol, and A.K. Jha. 
"Electronic Health Records' Limited Successes Suggest More Targeted 
Uses." Health Affairs, vol. 29, no. 4 (2010): 639-646. 

Methodology: The researchers created a survey and surveyed 4,840 acute-
care general medical and surgical hospitals from March to September 
2008 that were members of the American Hospital Association. The 
researchers linked the information gathered in their survey to 
information from three other data sources. 

How electronic prescribing was determined: Whether the hospital had a 
comprehensive EHR, defined as an EHR with 24 clinical functions used 
across all major clinical units in the hospital, a basic EHR system, 
defined as a system with 10 key functions in at least one major 
clinical unit in the hospital, or no EHR system. 

Outcome(s) measured: (1) Performance on quality metrics based on data 
released from the Hospital Quality Alliance for three clinical 
conditions--acute myocardial infarction, congestive heart failure, and 
pneumonia--and prevention of surgical complications, and (2) 
efficiency, as measured by the hospitals' risk-adjusted length of 
stay, risk-adjusted 30-day readmission rates, and risk-adjusted 
inpatient costs, which were determined using two sources of data, the 
Medicare Inpatient Impact File and the Area Resource File. 

Reported findings: (1) No relationships were found between EHR 
adoption and quality process measures for acute myocardial infarction, 
congestive heart failure, pneumonia, or 30-day risk-standardized 
mortality of these conditions. Hospitals with EHR had somewhat better 
performance on the prevention of surgical complications measures than 
hospitals without EHR (93.7 percent for hospitals with a comprehensive 
EHR, 93.3 percent for hospitals with a basic EHR, and 92.0 percent for 
those without EHR). (2) No relationships between the level of EHR 
adoption and overall risk-adjusted length of stay were found. 
Hospitals with comprehensive EHRs had similar rates of readmissions 
within 30 days of hospital discharge compared to hospitals with basic 
or no EHRs. The researchers found that hospitals with such systems had 
comparable inpatient costs to hospitals without them. Pneumonia 
patients in hospitals with a comprehensive EHR had a length of stay 
that was, on average, 0.5 days shorter than those of patients in 
hospitals without EHR. 

Other issues: In this article, CDS consisted of clinical reminders and 
clinical practice guidelines and was associated with marginally better 
performance on each of the Hospital Quality Alliance quality metrics. 

Devine, E.B., R.N. Hansen, J.L. Wilson-Norton, N.M. Lawless, A.W. 
Fisk, D.K. Blough, D.P. Martin, and S.D. Sullivan. "The Impact of 
Computerized Provider Order Entry on Medication Errors in a 
Multispecialty Group Practice." Journal of the American Medical 
Informatics Association, vol. 17, no. 1 (2010): 78-84. 

Methodology: A pre-post study compared prescriptions written at a 
multilocation clinic before and after the implementation of a CPOE 
system. For the pre-CPOE implementation period between March 1, 2002, 
and July 15, 2002, for one clinic and between January 2, 2004, and 
March 4, 2004, for other clinics, 5,016 prescriptions were evaluated. 
For the post-CPOE implementation period between January 14, 2004, and 
July 13, 2004, for one clinic and between July 1, 2005, and April 26, 
2006, for other clinics, 5,153 prescriptions were evaluated. 

How electronic prescribing was determined: Whether the prescription 
was written before or after the implementation of the CPOE system. 

Outcome(s) measured: (1) Rates, (2) types, and (3) severity of errors 
in prescriptions written before CPOE system implementation compared to 
prescriptions submitted electronically after the implementation of the 
CPOE system. 

Reported findings: (1) Rates of errors in prescriptions declined from 
18.2 percent before to 8.2 percent after implementation of the CPOE 
system, and the adjusted odds of an error occurring postimplementation 
of CPOE system were 70 percent lower than preimplementation. (2) There 
were reductions in the adjusted odds of the following error types: 
illegibility (97 percent), inappropriate abbreviations (94 percent), 
information missing (85 percent), wrong strength (81 percent), drug- 
disease interaction (79 percent), and drug-drug errors (76 percent). 
(3) Electronic prescribing led to a 57 percent decrease in the odds of 
an error occurring that did not cause harm. There was a 49 percent 
reduction in the odds of errors occurring that caused harm. The 
authors note that this reduction was not significant and that the 
small number of errors in this category could have caused this result 
to not be significant. 

Other issues: The CPOE had limited CDS alerts that included basic 
dosing guidance and duplicate therapy checks. 

Feldstein, A.C., D.H. Smith, N. Perrin, X. Yang, S.R. Simon, M. Krall, 
D.F. Sittig, D. Ditmer, R. Platt, and S.B. Soumerai. "Reducing 
Warfarin Medication Interactions: An Interrupted Time Series 
Evaluation." Archives of Internal Medicine, vol. 166, no. 9 (2006): 
1009-1015. 

Methodology: A pre-post study of 239 primary care providers with 9,910 
patients taking Warfarin at 15 primary care clinics that implemented 
medication interaction alerts for the drug Warfarin into their 
electronic medical records with computerized order entry and decision 
support. The baseline period was from January 2000 through November 
2002 and the postintervention period was from April 2003 through 
August 2004. 

How electronic prescribing was determined: The presence of electronic 
medical record alerts for selected coprescriptions of medications that 
interact with Warfarin. When Warfarin and a targeted interacting 
medication were coprescribed, an alert would appear, whereupon the 
clinician had to click "OK" to continue prescribing the interacting 
medication or prescribe a different drug. 

Outcome(s) measured: The interacting prescription rate, defined as the 
number of coprescriptions of Warfarin-interacting medications per 
10,000 Warfarin users per month. 

Reported findings: At baseline, about a third of patients had an 
interacting prescription. Coinciding with the implementation of the 
alerts, the estimated Warfarin-interacting medication prescription 
rate decreased from 3,294 interacting prescriptions per 10,000 
Warfarin users to 2,804 interacting prescriptions per 10,000 Warfarin 
users, resulting in a 14.9 percent relative reduction. 

Other issues: The electronic medical record had CDS in the form of 
medication alerts. 

Galanter, W.L., R.J. Didomenico, and A. Polikaitis. "A Trial of 
Automated Decision Support Alerts for Contraindicated Medications 
Using Computerized Physician Order Entry." Journal of the American 
Medical Informatics Association, vol. 12, no. 3 (2005): 269-274. 

Methodology: A comparison, pre-post study of a CPOE alert designed to 
appear when a clinician attempted to order potentially contraindicated 
drugs for patients with decreased kidney function through the CPOE. 
The study was conducted with 233 patients over an 18 month period (4-
month pre-CPOE alert period and 14-month post-CPOE alert period). 

How electronic prescribing was determined: Whether or not CPOE alerts 
were generated when contraindicated drugs were ordered electronically. 

Outcome(s) measured: (1) The likelihood of a contraindicated drug 
being administered before and after implementation of the CPOE alerts, 
as collected from electronic medical records. (2) Alert compliance. 

Reported findings: (1) Likelihood of a patient receiving at least one 
dose of the contraindicated medication decreased from 89 percent in 
the prealert period to 47 percent in the postalert period. (2) Patient 
gender was associated with alert compliance rate, with compliance in 
female patients lower than that in male patients. Alert compliance 
also decreased as kidney function increased. House staff with more 
than 1 year of residency training had a higher compliance rate than 
those with less than 1 year of training. 

Gandhi, T.K., S.N. Weingart, A.C. Seger, J. Borus, E. Burdick, E.G. 
Poon, L.L. Leape, and D.W. Bates. "Outpatient Prescribing Errors and 
the Impact of Computerized Prescribing." Journal of General Internal 
Medicine, vol. 20, no. 9 (2005): 837-841. 

Methodology: A comparison study of 1,879 prescriptions reviewed by a 
pharmacist and submitted at four adult primary care practices, two of 
which utilized electronic prescribing and two that did not, over a 
period of 7 months (September 1999 to March 2000). 

How electronic prescribing was determined: Whether prescriptions were 
written at computerized or noncomputerized sites. 

Outcome(s) measured: Rates of (1) prescribing errors and (2) potential 
adverse drug events as determined by the expert reviewers from 
conducting prescription reviews, chart reviews, and conducting patient 
surveys. 

Reported findings: (1) Sites with electronic prescribing contained 
errors in 4.3 percent of prescriptions, compared to 11.0 percent of 
prescriptions written at sites without electronic prescribing. (2) 
Sites with electronic prescribing contained potential ADEs in 2.6 
percent of prescriptions, compared to 4.0 percent of prescriptions at 
sites without electronic prescribing. The authors note that the 
differences between the two groups in errors and prevented ADEs were 
not significant, but that the rates of prescribing errors and 
prevented ADEs could have been substantially reduced with more 
advanced CDS. 

Other issues: The system provided no automatic checks for correct 
doses, frequencies, allergies, or drug interactions, and authors found 
that decision support (such as drug-dose checking and drug-frequency 
checking) could have prevented 97 percent of prescribing errors and 95 
percent of potential ADEs. 

Kaushal, R., A.K. Jha, C. Franz, J. Glaser, K.D. Shetty, T. Jaggi, B. 
Middleton, G.J. Kuperman, R. Khorasani, M. Tanasijevic, and D.W. 
Bates. "Return on Investment for a Computerized Physician Order Entry 
System." Journal of the American Medical Informatics Association, vol. 
13, no. 3 (2006): 261-266. 

Methodology: A cost-benefit assessment of the implementation of CPOE 
with CDS at Brigham and Women's Hospital, a 720-adult bed tertiary 
care medical center in Boston from 1993 through 2002. Determined the 
capital and operational costs of implementing a CPOE with CDS and of 
each CDS intervention through internal documents and interviews with 
the CPOE developers and reviewing published literature. 

How electronic prescribing was determined: Whether or not the CDS 
intervention was active. 

Outcome(s) measured: Identified cost savings associated with specific 
CDS interventions. GAO grouped the savings into those resulting from: 
(1) decreased ADEs and (2) decreased drug costs. 

Reported findings: Of the estimated $28.5 million in estimated savings 
from the CPOE, (1) $12.9 million in estimated savings were due to CDS 
interventions that reduced ADEs, and (2) $6 million in estimated 
savings were due to CDS interventions that reduced drug costs. The 
cost to develop, implement, and operate the CPOE was $11.8 million, 
resulting in cumulative savings of $16.7 million. 

Other issues: The CPOE was equipped with CDS. 

Kaushal, R., L.M. Kern, Y. Barrón, J. Quaresimo, and E.L. Abramson. 
"Electronic Prescribing Improves Medication Safety in Community-Based 
Office Practices." Journal of General Internal Medicine, vol. 25, no. 
6 (2010): 530-536. 

Methodology: A pre-post study of 30 ambulatory care providers (15 
electronic prescribers and 15 paper prescribers) in 12 practices in 
Hudson Valley region of New York (conducted from September 2005 to 
June 2007). The researchers collected 2 weeks of carbon copies and 
downloads of prescriptions to identify medication errors at baseline 
and 1 year follow-up and compared error rates among and between the 
electronic and paper prescriber groups. 

How electronic prescribing was determined: Whether or not the 
physicians' medication orders were handwritten or submitted 
electronically through a stand-alone electronic prescribing system as 
identified through the carbon copies of prescriptions or prescription 
downloads. 

Outcome(s) measured: (1) Medication prescribing errors (including 
omitting the quantity or incorrect medication dose and duration), (2) 
illegibility errors, (3) near misses (i.e., potentially harmful errors 
that were intercepted or reached the patient but caused no harm), (4) 
ADEs, (5) rule violations (e.g., failing to write "po" for a 
medication taken orally), and (6) effects of CDS on medication errors. 

Reported findings: (1) The medication prescribing error rate among 
electronic prescribers decreased from 42.5/100 prescriptions at 
baseline to 6.6/100 prescriptions at 1 year follow-up. Electronic 
prescribers had a lower medication prescribing error rate than paper 
prescribers (6.6/100 v. 38.4/100). (2) Electronic prescribing 
eliminated all illegibility errors. (3) Electronic prescribers had 
fewer near misses (1.3/100 v. 2.7/100) than paper prescribers. (4) 
Rates of preventable adverse drug events trended lower among 
electronic prescribers (0.04 vs. 0.26 per 100 prescriptions). The 
authors noted that this was not a significant difference between 
electronic and paper prescribers. (5) Electronic prescribing 
eliminated nearly all types of rule violation errors. (6) Electronic 
prescribers had fewer errors judged preventable by advanced/basic CDS 
than paper prescribers at 1 year than paper prescribers. 

Other issues: The stand-alone electronic prescribing system was 
equipped with CDS. 

Kim, G.R., A.R. Chen, R.J. Arceci, S.H. Mitchell, K.M. Kokoszka, D. 
Daniel, and C.U. Lehmann. "Error Reduction in Pediatric Chemotherapy: 
Computerized Order Entry and Failure Modes and Effects Analysis." 
Archives of Pediatrics and Adolescent Medicine, vol. 160 (2009): 495-
498. 

Methodology: A pre-post study of chemotherapy orders written in a 
pediatric oncology unit. The study compared 1,259 paper orders written 
before implementation of the CPOE system (from July 31 to August 1, 
2001, and from August 14, 2001, to August 22, 2002) to 1,116 
electronic orders written after implementation of the CPOE system 
(from February 3, 2003, to February 12, 2004). 

How electronic prescribing was determined: Whether the orders were 
submitted before or after the implementation of the CPOE. A paper 
based survey was used to capture the pre-CPOE data, and the post-CPOE 
data were captured through the system. 

Outcome(s) measured: Data on chemotherapy steps of high morbidity/ 
mortality potential if missed, as determined by attending oncologists. 

Reported findings: Findings reported by the study included: after CPOE 
implementation, daily chemotherapy orders (1) were less likely to have 
improper dosing, incorrect dosing calculations, missing cumulative 
dose calculations, and incomplete nursing checklists, and (2) had a 
higher likelihood of not matching medication orders to treatment plans. 

Ko, Y., J. Abarca, D.C. Malone, D.C. Dare, D. Geraets, A. Houranieh, 
W.N. Jones, W.P. Nichol, G.P. Schepers, M. Wilhardt. "Practitioners' 
Views on Computerized Drug-Drug Interaction Alerts in the VA System." 
Journal of the American Medical Informatics Association, vol. 14, no. 
1 (2007): 56-64. 

Methodology: A survey of 258 prescribers and 84 pharmacists from seven 
VA Medical Centers across the United States. The time period of the 
survey was between 2004 and 2005. 

How electronic prescribing was determined: Survey participants had 
prescribing authority in a VA Medical Center and an active outpatient 
practice. In the VA's computerized patient record system, prescribers 
enter prescription orders electronically for review and verification 
by a pharmacist before dispensing. 

Outcome(s) measured: The survey asked respondent a variety of 
questions including those related to (1) respondent satisfaction with 
the combined inpatient and outpatient CPOE system (the computerized 
patient record system), (2) attitude towards drug-drug interaction 
alerts, and (3) suggestions for improving drug-drug interaction alerts. 

Reported findings: Findings reported in the study included the 
following: (1) in general, both prescribers and pharmacists indicated 
that the computerized patient record system had a positive effect on 
their jobs. Pharmacists revealed more favorable attitudes toward 
computerized patient record system than prescribers. (2) Sixty-one 
percent of prescribers felt that drug-drug interaction alerts had 
increased their potential to prescribe safely. Thirty percent of 
prescribers felt that drug-drug interaction alerts provided them with 
exactly what they needed most of the time. (3) Both prescribers and 
pharmacists agreed that drug-drug interaction alerts should be 
accompanied by management alternatives (73 percent and 82 percent, 
respectively) and more detailed information (65 percent and 89 
percent, respectively). 

Kocakulah, M.C., and J. Upson. "Cost Analysis of Computerized 
Physician Order Entry Using Value Stream Analysis: A Case Study." 
Research in Healthcare Financial Management, vol. 10, no. 1 (2005): 13-
25. 

Methodology;: A case study of a 400-bed urban hospital, using value-
stream mapping to conduct a cost analysis of a CPOE system. The study 
determined the potential costs and adverse drug reaction reductions 
related to CPOE implementation in this hospital, which did not have 
CPOE installed. 

How electronic prescribing was determined: This hospital did not have 
an electronic prescribing or CPOE system. 

Outcome(s) measured: Using published studies or reports and data from 
the hospital, this study determined (1) the projected decrease in 
medication errors, (2) the potential net savings, (3) net present 
value, and (4) project internal rate of return for a CPOE system based 
on the severity, average cost, and projected reduction of adverse drug 
reactions. 

Reported findings: (1) The percentage of illegible orders is projected 
to decrease by 78 percent, incomplete orders by 71 percent, incorrect 
orders by 46 percent, and drug therapy problems by 9 percent. (2) The 
projected net savings were $155,686 per year. (3) The projected 
project 5-year net present value was a negative $1,270,112. (4) The 
projected 5-year internal rate of return was negative 24 percent. 
Because of these projections, the authors did not recommend the 
hospital invest in a CPOE system at the current time. 

McCullough, J.S., M. Casey, I. Moscovice, and S. Prasad. "The Effect 
of Health Information Technology on Quality in U.S. Hospitals." Health 
Affairs, vol. 29, no. 4 (2010): 647-654. 

Methodology: A comparison study of 3,401 nonfederal acute-care U.S. 
hospitals from 2004 to 2007. 

How electronic prescribing was determined: Whether the hospital had an 
EHR and a CPOE system, as identified from information from the 
American Hospital Association's annual survey and the HIMSS analytics 
database that describes hospitals' health information technology 
adoption decisions. 

Outcome(s) measured: 629-638.: Performance on six process quality 
measures in the CMS Hospital Compare database. 

Reported findings: For nearly all measures, average quality was higher 
for hospitals with EHR and CPOE (with larger effects for academic 
hospitals than when compared to all hospitals). However, the 
difference was only significant for pneumococcal vaccine 
administration (2.1 percent increase) and use of the most appropriate 
antibiotic for pneumonia (1.3 percent increase). 

Other issues: The study defined an EHR as a set of applications 
including a computerized patient record with a clinical data 
repository and some CDS capabilities, such as providing treatment 
recommendations. 

McMullin, S.T., T.P. Lonergan, and C.S. Rynearson. "Twelve-Month Drug 
Cost Savings Related to Use of an Electronic Prescribing System with 
Integrated Decision Support in Primary Care." Journal of Managed Care 
Pharmacy, vol. 11, no. 4 (2005): 322-332. 

Methodology: A comparison study of 38 primary care clinicians (19 
electronic prescribing system users; 19 electronic prescribing system 
nonusers) conducted from June 2002 through May 2003. 

How electronic prescribing was determined: Whether or not the 
physician was using an electronic prescribing system with CDS 
capabilities as identified through the study design. 

Outcome(s) measured: Using pharmacy claims, determined (1) if the 6-
month savings on new prescriptions were sustained during the 12-months 
of follow-up, (2) the 12-month cost savings associated with CDS on 
pharmacy claims, and (3) prescribing behavior of clinicians on eight 
high-cost therapeutic groups targeted by electronic messages to 
prescribers. 

Reported findings: (1) Savings seen in the last 6 months of the 12 
month follow-up period were greater than the first 6 months ($748 per-
member-per-month at 6 months to $794 at 12 months per-member-per-
month). (2) Use of the electronic prescribing system was associated 
with a sustained decrease in prescription costs. Over the 12 month 
follow-up period, the average cost per new prescription for the 
intervention group decreased by $1.00 and increased by $3.75 in the 
control group. The number of other refilled prescriptions decreased 
more in the intervention group than in the control group. The number 
of new prescriptions increased slightly more in the intervention group 
than the controls. (3) Prescriptions for high-cost target medications 
overall decreased by 9.1 percent in the intervention group because of 
CDS and increased in the control group by 8.2 percent. Compared with 
the control group, the prescription ratio for high-cost drug classes 
was a relative 17.5 percent lower in the group using the CDS (35.8 
percent versus 43.4 percent). 

Other issues: The electronic prescribing system had integrated CDS, 
formulary, payor, and clinical guideline alert messaging capabilities. 

Peterson, J.F., G.J. Kuperman, C. Shek, M. Patel, J. Avorn, and D.W. 
Bates. "Guided Prescription of Psychotropic Medications for Geriatric 
Inpatients." Archives of Internal Medicine, vol. 165, no. 7 (2005): 
802-807. 

Methodology: A comparison study at a tertiary care hospital, including 
3,718 patients 65 years or older that were prescribed a psychotropic 
medication targeted in the intervention and admitted for medical, 
surgical, neurology, or gynecology services from October 8, 2001, to 
May 16, 2002. 

How electronic prescribing was determined: Whether the geriatric 
decision support system, which included medication dosing and 
selection guidelines for elderly patients, was activated. 

Outcome(s) measured: The study measured several outcomes including: 
(1) The rate at which prescriptions were written in agreement with 
expert recommendations regarding recommended daily dose for the 
initial drug order, (2) incidence of dosing at least 10-fold greater 
than the recommended daily dose, and (3) prescription of 
nonrecommended drugs. 

Reported findings: Findings presented included: (1) The prescriptions 
for psychotropic medications agreed with the system recommendations 
for dosing more frequently during the intervention periods when the 
geriatric decision support application was available. The agreement 
rate for both control periods was lower than the agreement rate for 
the intervention periods. (2) During the intervention periods, the 
incidence of 10-fold dosing decreased from 5.0 percent to 2.8 percent, 
(3) the prescription of nonrecommended drugs decreased from 10.8 
percent to 7.6 percent. 

Ross, S.M., D. Papshev, E.L. Murphy, D.J. Sternberg, J. Taylor, and R. 
Barg. "Effects of Electronic Prescribing on Formulary Compliance and 
Generic Drug Utilization in the Ambulatory Care Setting: A 
Retrospective Analysis of Administrative Claims Data." Journal of 
Managed Care Pharmacy, vol. 11, no. 5 (2005): 410-415. 

Methodology: A comparison study of 110,975 paid pharmacy claims 
submitted by two groups--95 providers using predominantly electronic 
prescribing and a matched sample of 95 providers who did not 
electronically prescribe--between August 1, 2001, and July 31, 2002. 

How electronic prescribing was determined: Whether or not a provider 
used electronic prescribing during the study period. 

Outcome(s) measured: (1) Formulary compliance, which was assessed 
using the formulary code field in pharmacy data claims, and (2) 
generic utilization rates, which was assessed using First DataBank 
National Drug Data File Plus software to determine the brand or 
generic status of each drug. 

Reported findings: (1) Formulary compliance for both groups was 
similar. The electronic prescribing group was 83.2 percent compliant, 
compared to 82.8 percent compliance in the group that did not 
electronically prescribe. (2) Generic utilization rates were also 
similar, 37.3 percent for those who electronically prescribed and 36.9 
percent for those that did not. 

Other issues: The electronic prescribing system provided drug and 
formulary information during the prescribing process. 

Spencer, D.C., A. Leininger, R. Daniels, R. Granko, and R.R. Coeytaux. 
"Effect of a Computerized Prescriber-Order-Entry System on Reported 
Medication Errors." American Journal of Health-System Pharmacy, vol. 
62, no. 4 (2005): 416-419. 

Methodology: A pre-post study and comparison of two medicine units at 
an academic hospital before and after implementation of a CPOE with 
CDS, compared to units in the hospital that did not implement a CPOE 
system. Data were collected over a period of 16 months. 

How electronic prescribing was determined: Whether the medication 
error was reported before or after the implementation of the CPOE 
system in two medicine units of the hospital and whether or not the 
medication error was reported from the two medicine units of the 
hospital that implemented CPOE. 

Outcome(s) measured: Reported medication errors and potential 
medication errors, as obtained from the hospital's center for 
medication safety. 

Reported findings: Implementation of the CPOE system in the two units 
was associated with an increase in reported errors, from 0.068 per 
discharge preimplementation to 0.088 per discharge after 
implementation. The units in the hospital that did not implement CPOE 
systems had a decrease in the number of reported errors from 0.133 per 
discharge to 0.079 per discharge. 

Other issues: The authors note that while the error rates increased in 
the units with CPOE, the error rates in the units in the hospital 
without CPOE decreased. Therefore, the increase in reported medication 
errors on units with CPOE systems may have been attributable to the 
direct or indirect consequences of introduction of the CPOE system. 

Steele, A.W., S. Eisert, J. Witter, P. Lyons, M.A. Jones, P. Gabow, 
and E. Ortiz. "The Effect of Automated Alerts on Provider Ordering 
Behavior in an Outpatient Setting." PLoS Medicine, vol. 2, no. 9 
(2005): 864-870. 

Methodology: A pre-post study of the implementation and effect of 
alerts generated during medication ordering in primary care clinics. 
The baseline data were collected from August 1, 2002, to November 29, 
2002, and the postintervention data were collected from December 1, 
2002, to April 30, 2003. 

How electronic prescribing was determined: All provider staff entered 
medication orders using CPOE. The study design compared baseline 
ordering behavior (when no alert was triggered) to ordering behavior 
after alerts were triggered. 

Outcome(s) measured: (1) The number of medication orders not completed 
in response to an alert, (2) the number of rule-associated laboratory 
test orders initiated after an alert was displayed, as captured in the 
electronic prescribing system, and (3) the rates of adverse drug 
events assessed by completing file reviews on a random sample of 
medication orders. 

Reported findings: (1) Before the alerts were implemented, prescribers 
did not complete medication orders 5.4 percent of the time, compared 
to 8.3 percent of the time after the alerts were implemented. The 
authors noted that this was not a significant difference between the 
groups. When the alert was for an abnormal laboratory value, the 
percentage of times where the medication order was not completed 
increased from 5.6 percent at baseline to 10.9 percent during the 
intervention. (2) Comparing the pre-and postintervention periods for 
medication orders when no alert was displayed, prescribers ordered 
associated laboratory tests 17 percent of the time during the 
preintervention period, compared to 16.2 percent of the time in the 
postintervention period. The authors state that this finding was not 
significant and indicates that there was no trend, in general, to 
increased laboratory test ordering during the study period. (3) The 
preintervention group had a potential ADE in 10.3 percent of charts 
compared to in 4.3 percent of the charts in the postintervention 
group. The authors state that the difference between the groups was 
not significant and that the study was too small to show for sure 
whether there was any true effect on adverse drug reactions. 

Stone, W.M., B.E. Smith, J.D. Shaft, R.D. Nelson, and S.R. Money. 
"Impact of a Computerized Physician Order-Entry System." Journal of 
the American College of Surgeons, vol. 208, no. 5 (2009): 960-969. 

Methodology: A pre-post study of patient-safety measures before and 
after CPOE implementation at the Mayo Clinic Hospital in Phoenix, 
Arizona. The CPOE system was implemented from May 8, 2007, to April 
30, 2008. 

How electronic prescribing was determined: Whether or not the 
physicians' orders were submitted electronically using the CPOE system. 

Outcome(s) measured: (1) Medication errors and (2) order-
implementation time. 

Reported findings: (1) There were no significant differences in the 
rate of medication errors in any of the study time periods, which were 
captured through self-reporting. (2) The time from a doctor placing an 
order, which was recorded or captured electronically, to a nurse 
receiving that order decreased from 41.2 minutes pre-CPOE to 27 
seconds post-CPOE. 

Taylor, J.A., L.A. Loan, J. Kamara, S. Blackburn, and D. Whitney. 
"Medication Administration Variances Before and After Implementation 
of Computerized Physician Order Entry in a Neonatal Intensive Care 
Unit." Pediatrics, vol. 121, no. 1 (2008): 123-128. 

Methodology: A comparison, pre-post study of how the actual medication 
administration differed from the medication order before and after 
CPOE implementation. The study was conducted in the 30-bed Neonatal 
Intensive Care Unit at Madigan Army Medical Center from August 2004 to 
April 2006 (pre-CPOE: August 2004 to June 2005; post-CPOE: August 2005 
to April 2006). 

How electronic prescribing was determined: Whether or not the 
physicians' medication orders were handwritten or submitted 
electronically using a CPOE system. 

Outcome(s) measured: (1) Differences between the medication order and 
how the medication was actually administered. (2) Reasons for 
variances between the medication order and administration, as noted by 
the research nurses. 

Reported findings: (1) The variation between the medication order and 
how the medication was actually administered was lower post-CPOE than 
pre-CPOE (11.6 percent and 19.8 percent, respectively). (2) Findings 
related to rates of variance in medication order and administration in 
the pre-and post-CPOE included the following: similar variances in 
both periods were found for administration mistakes, pharmacy 
problems, and prescribing problems; and variances related to 
administration of drugs by the wrong route and the wrong time were 
significantly lower after CPOE implementation. 

Other issues: The CPOE utilized CDS and display formats and defaults 
configured specifically for use in the Neonatal Intensive Care Unit 
for ordering prescriptions. 

Upperman, J.S., P. Staley, K. Friend, W. Neches, D. Kazimer, J. Benes, 
and E.S. Wiener. "The Impact of Hospitalwide Computerized Physician 
Order Entry on Medical Errors in a Pediatric Hospital." Journal of 
Pediatric Surgery, vol. 40, no.1 (2005): 57-59. 

Methodology: A pre-post study comparing orders written before the 
implementation of a CPOE system in a children's hospital from January 
2002 to October 2002 to those written after the implementation of CPOE 
system in November 2003 (the end point of the study period was not 
specified). 

How electronic prescribing was determined: Whether a prescription was 
written before or after the implementation of CPOE. 

Outcome(s) measured: The rate and types of ADEs determined by 
analyzing data collected at the hospital. 

Reported findings: ADE rates pre-CPOE were 0.3 per 1,000 doses, 
compared to 0.37 per 1,000 doses post-CPOE. The authors note that the 
study demonstrates a substantial decrease in harmful ADEs, but no 
significant difference in all ADEs between the pre-and post-CPOE 
periods. The rate of harmful ADEs pre-CPOE were 0.05 per 1,000 doses, 
compared to 0.03 per 1,000 doses post-CPOE. 

Other issues: The CPOE had CDS. 

Vaidya, V., A.K. Sowan, M.E. Mills, K. Soeken, M. Gaffoor, and E. 
Hilmas. "Evaluating the Safety and Efficiency of a CPOE System for 
Continuous Medication Infusions in a Pediatric ICU." AMIA Symposium 
Proceedings, 2006. 

Methodology: A comparison study evaluating the safety of a CPOE system 
compared to a handwritten, hand-calculated method for prescribing 
continuous drug infusions for pediatric ICU patients. The time period 
of the study was not specified. 

How electronic prescribing was determined: Whether the orders for the 
drug infusions were generated in the CPOE system or through a 
handwritten, hand-calculated method. 

Outcome(s) measured: The (1) occurrence and (2) risk level of errors, 
as identified through a review of order sheets for errors. 

Reported findings: (1) The drug infusion orders generated using the 
CPOE system had fewer errors (4.3 percent) than those that were 
handwritten (73 percent). (2) Twenty-five percent of the errors in the 
handwritten group were judged to be "high-risk" compared to 0 percent 
in the CPOE group. All of the errors in the CPOE group were missing 
signatures. 

Other issues: The CPOE included decision support. 

Varkey, P., P. Aponte, C. Swanton, D. Fischer, S.F. Johnson, and M.D. 
Brennan. "The Effect of Computerized Physician-Order Entry on 
Outpatient Prescription Errors." Managed Care Interface, vol. 20, no. 
3 (2007): 53-57. 

Methodology: A retrospective survey of 4,527 prescriptions ordered 
from March 1996 through March 2002 at Mayo Clinic ambulatory clinics 
comparing prescriptions ordered through the clinic's CPOE to 
handwritten orders. 

How electronic prescribing was determined: Whether or not the type of 
prescription generated was handwritten, computerized, or preprinted. 

Outcome(s) measured: The (1) prevalence and (2) type of pharmacist- 
intercepted prescription errors in computerized and handwritten 
prescriptions. 

Reported findings: (1) The frequency of intercepted prescription 
errors were highest in handwritten prescriptions (7.4 percent), 
followed by computerized prescriptions (4.9 percent), and preprinted 
prescriptions (1.7 percent). (2) The most commonly intercepted 
prescriptions involved the dosage form, dispense quantity, medication 
dosage, and drug allergies. CPOE resulted in lower rates in every type 
of intercepted prescription error, including form, dosage, quantity, 
allergy, frequency, drug name, patient name, illegibility, route, and 
drug-drug interaction, compared to handwritten prescriptions. 

Other issues: The CDS included required fields and duplicate order 
checking. 

Wang, C.J., M.H. Patel, A. Schueth, M. Bradley, S. Wu, J.C. Crosson, 
P.A. Glassman, and D.S. Bell. "Perceptions of Standards-based 
Electronic Prescribing Systems as Implemented in Outpatient Primary 
Care: A Physician Survey." Journal of the American Medical Informatics 
Association, vol. 16, no. 4 (2009): 493-502. 

Methodology: Cross-sectional survey of physicians was fielded from 
October 2006 to December 2006 among physicians enrolled in a Blue 
Cross Blue Shield electronic prescribing sponsorship program. 

How electronic prescribing was determined: Whether or not the 
physician had installed an electronic prescribing system. 

Outcome(s) measured: (1) Adequacy of available drug formulary and 
medication history information and (2) perceptions of the electronic 
prescribing system's enhancement of job performance. 

Reported findings: (1) Electronic prescribing users were more likely 
than nonusers to "agree" or "strongly agree" that the information 
available about the patient's medication history helps them to 
identify clinically important drug-drug interactions and prevent 
callbacks from pharmacies for safety problems. Electronic prescribing 
users were slightly more favorable toward statements that electronic 
prescribing system drug coverage helps patients maintain lower drug 
costs. (2) Sixty-two percent of electronic prescribers "agreed" or 
"strongly agreed" that electronic prescribing improves the quality of 
care they can deliver. 

Weingart, S.N., B. Simchowitz, L. Shiman, D. Brouillard, A. Cyrulik, 
R.B. Davis, T. Isaac, M. Massagli, L. Morway, D.Z. Sands, J. Spencer, 
and J.S. Weissman. "Clinicians' Assessments of Electronic Medication 
Safety Alerts in Ambulatory Care." Archives of Internal Medicine, vol. 
169, no. 17 (2009): 1627-1632. 

Methodology: A survey mailed to 300 clinicians in December 2007 about 
the value of electronic prescribing. 

How electronic prescribing was determined: Whether clinicians adopted 
a commercial electronic prescribing system with a drug-allergy and 
interaction alerts drug reference database and used the electronic 
prescribing system to write at least 100 prescriptions per month 
between January 1 and June 30, 2006. 

Outcome(s) measured: (1) Clinicians' satisfaction with electronic 
prescribing and (2) perceptions of the effects of electronic 
prescribing and alerts on the safety, efficiency, and cost of care. 

Reported findings: (1) Forty-seven percent were satisfied or very 
satisfied with medication safety alerts. Clinicians said electronic 
prescribing would improve the quality of care delivered (78 percent); 
prevent medical errors (83 percent); enhance patient satisfaction (71 
percent); and improve clinician efficiency (75 percent). (2) Seventy- 
eight percent said at least one alert had caused them to change their 
behavior in the past 6 months. Fifty-seven percent said an alert might 
have prevented at least one error or injury in the average month. 
Twenty-two percent said an alert had prevented a serious error or 
injury in their practice. Sixty-three percent of respondents said an 
alert caused them to take action other than change an alerted 
prescription (counsel patient, look up information in a drug 
reference, or change how they monitor a patient). The study also 
reported participant ratings on potential problems associated with the 
drug allergy or interaction alerts. For example, 58 percent of 
respondents reported that alerts were triggered by discontinued 
medications. 

Yu, F.B., N. Menachemi, E.S. Berner, J.J. Allison, N.W. Weissman, and 
T.K. Houston. "Full Implementation of Computerized Physician Order 
Entry and Medication Related Quality Outcomes: A Study of 3364 
Hospitals." American Journal of Medical Quality, vol. 24, no. 4 
(2009): 278-286. 

Methodology: A comparison study of hospitals--264 that used a CPOE 
system to enter all orders and 3,100 that did not--over a 1-year 
period (July 2003 to June 2004). 

How electronic prescribing was determined: Whether the hospital 
reported on the HIMSS analytics survey that it entered all orders 
through CPOE. 

Outcome(s) measured: Performance on hospital quality-of-care measures 
from CMS. 

Reported findings: Of the 11 medication-related measures, the mean 
performance on 6 cardiovascular-related measures was higher among CPOE 
hospitals than non-CPOE hospitals, and the mean performance on one 
measure, antibiotics within 4 hours of arrival, was lower among CPOE 
hospitals than non-CPOE hospitals. 

Yu, F., M. Salas, Y. Kim, and N. Menachemi. "The Relationship Between 
Computerized Physician Order Entry and Pediatric Adverse Drug Events: 
A Nested Matched Case-Control Study." Pharmacoepidemiology and Drug 
Safety, vol. 18, no. 8 (2009): 751-755. 

Methodology: A comparison study between 54 pediatric hospitals that 
had CPOE systems and 68 pediatric hospitals that did not. Patient data 
were retrieved between October 1, 2005, and September 30, 2006. 

How electronic prescribing was determined: Whether a CPOE system was 
fully implemented for all orders and clinical domains, as identified 
through the HIMSS analytics database. 

Outcome(s) measured: The odds of ADEs, using data from the national 
association of children's hospitals and related institutions case-mix 
comparative data program and HIMSS. 

Reported findings: The odds of experiencing an ADE were 42 percent 
higher for hospitals without CPOE compared to those with CPOE. 

Zhan C., R.W. Hicks, C.M. Blanchette, M.A. Keyes, and D.D. Cousins. 
"Potential Benefits and Problems with Computerized Prescriber Order 
Entry: Analysis of a Voluntary Medication Error-Reporting Database." 
American Journal of Health-System Pharmacy, vol. 63, no. 4. (2006): 
353-358. 

Methodology: Comparison study of 120 facilities that reported having a 
CPOE in all clinical areas to 339 facilities that did not have a CPOE. 
Facilities included general community hospitals, specialty hospitals, 
and outpatient clinics. Data analyzed were from 2003. 

How electronic prescribing was determined;: Whether the facility had 
CPOE, as determined by Medmarx, a national voluntary medication-error 
reporting database. 

Outcome(s) measured: (1) The number of errors reported by CPOE versus 
non-CPOE facilities and (2) the characteristics of errors caused by 
CPOE, as captured in the Medmarx database. 

Reported findings: The authors stated that the different facilities 
that self-reported data to the Medmarx database appeared to have 
different levels of underreporting of medication errors, and 
therefore, these data cannot be used to assess the potential benefits 
of CPOE or compare rates of medication errors between providers though 
facilities with CPOE had fewer inpatient errors, more outpatient 
errors, and smaller numbers of outpatient and inpatient errors that 
reached or harmed patients compared to facilities without CPOE. The 
article did not evaluate the sophistication of the CDS employed by the 
studied CPOE systems. 

[End of table] 

[End of section] 

Appendix III: Scope and Methodology: 

This appendix provides additional details regarding our scope and 
methodology for reporting information on the providers who 
participated in and received incentive payments from the 2009 
Electronic Prescribing Program. 

To conduct our analyses, we analyzed four Centers for Medicare & 
Medicaid Services (CMS) files. 

* 2009 Electronic Prescribing Program Participation. We obtained a 
file from CMS in October 2010 that provided summary information for 
each provider that participated in the Electronic Prescribing Program 
in 2009, which CMS also used to make payments to providers for 
2009.[Footnote 85] For each combination of national provider 
identifier and tax identification number,[Footnote 86] this file 
contained the following information: the total number of times each of 
the three electronic prescribing codes were submitted;[Footnote 87] 
the total number of applicable visits; whether CMS determined that the 
provider would receive an incentive payment; and the amount of the 
incentive payment. 

* 2009 Electronic Prescribing Program Eligible Providers. We obtained 
a file from CMS in October 2010 that listed each provider that had at 
least one applicable visit for the Electronic Prescribing Program in 
2009--which we refer to in this appendix as "applicable providers." 
Over 597,000 providers had at least one applicable visit for the 
Electronic Prescribing Program in 2009. This number represents a count 
of all Medicare providers who had at least one applicable visit in 
2009. However, not all of these providers have prescribing authority. 
Consequently, there may be some individuals included in the count of 
597,000 providers that were not eligible for an electronic prescribing 
incentive payment. 

* National Plan and Provider Enumeration System (NPPES) Downloadable 
File. We downloaded this file from CMS's Web site [hyperlink, 
http://nppes.viva-it.com/NPI_Files.html] in October 2010. We used the 
variable "Provider Business Practice Location Address State Name" to 
obtain the state for providers. 

* Provider Enrollment, Chain, and Ownership System (PECOS) Global 
Extract File. We obtained this file from CMS in October 2010. In the 
few cases when we were unable to obtain the state for providers using 
the NPPES Downloadable File, we attempted to determine the state for 
providers using either the "Practice Location State" variable or the 
"Correspondence Address State" variable from the PECOS Global Extract 
File. 

CMS determined which providers met or exceeded the reporting 
requirement for 2009 using each unique combination of providers' 
national provider identifiers and tax identification numbers. However, 
we analyzed and report information at the national provider identifier 
level only so that we could present results for unduplicated 
providers. We were unable to match 1,052 applicable providers (less 
than 0.2 percent of applicable providers) to either the NPPES 
Downloadable File or the PECOS Global Extract file.[Footnote 88] 

To determine the percent of Medicare providers who received incentive 
payments by state and the average incentive payment by state using the 
state for each provider, we obtained state information for over 99 
percent of applicable providers using data from the NPPES Downloadable 
File and for the remaining applicable providers using data from the 
PECOS Global Extract File. We excluded the about 0.2 percent of 
applicable providers mentioned above that we could not match to either 
the NPPES Downloadable File or the PECOS Global Extract File. In 
addition, we excluded about another 0.2 percent of applicable 
providers for whom we were unable to obtain state information, the 0.9 
percent of applicable providers who were from U.S. insular areas, and 
six providers whose state information we deemed unreliable.[Footnote 
89] 

[End of section] 

Appendix IV: Maximum Electronic Health Record (EHR) Program Incentive 
Payments, Based on First Year of Payment: 

First year provider participates in the EHR Program: 2011; 
Maximum EHR incentive payments by year[A]: 2011: $18,000; 
Maximum EHR incentive payments by year[A]: 2012: $12,000; 
Maximum EHR incentive payments by year[A]: 2013: $8,000; 
Maximum EHR incentive payments by year[A]: 2014: $4,000; 
Maximum EHR incentive payments by year[A]: 2015: $2,000; 
Maximum total incentive payment: $44,000. 

First year provider participates in the EHR Program: 2012; 
Maximum EHR incentive payments by year[A]: 2012: $18,000; 
Maximum EHR incentive payments by year[A]: 2013: $12,000; 
Maximum EHR incentive payments by year[A]: 2014: $8,000; 
Maximum EHR incentive payments by year[A]: 2015: $4,000; 
Maximum EHR incentive payments by year[A]: 2016: $2,000; 
Maximum total incentive payment: $44,000. 

First year provider participates in the EHR Program: 2013; 
Maximum EHR incentive payments by year[A]: 2013: $15,000; 
Maximum EHR incentive payments by year[A]: 2014: $12,000; 
Maximum EHR incentive payments by year[A]: 2015: $8,000; 
Maximum EHR incentive payments by year[A]: 2016: $4,000; 
Maximum total incentive payment: $39,000. 

First year provider participates in the EHR Program: 2014; 
Maximum EHR incentive payments by year[A]: 2014: $12,000; 
Maximum EHR incentive payments by year[A]: 2015: $8,000; 
Maximum EHR incentive payments by year[A]: 2016: $4,000; 
Maximum total incentive payment: $24,000. 

Source: GAO analysis of the Recovery Act. 

Notes: The Centers for Medicare & Medicaid Services (CMS) will 
increase the incentive payments by 10 percent each year for providers 
that predominantly furnish services in geographic areas designated as 
health professional shortage areas, such as areas that have a shortage 
of primary medical care. 

[A] Incentive payment amounts are equal to 75 percent of the 
provider's total allowed charges for services covered by Medicare Part 
B for the year, but are subject to the annual limits displayed in this 
table. 

[End of table] 

[End of section] 

Appendix V: Stage-One Reporting Requirements for the Electronic Health 
Records (EHR) Program: 

Mandatory requirements: 

1. Generate and transmit more than 40 percent of permissible 
prescriptions electronically.[A] 

2. Enter medication order into computerized physician order entry 
(CPOE) system for more than 30 percent of patients with at least one 
medication in their medication lists.[A] 

3. Enter medication lists or indicate no current prescriptions for 
more than 80 percent of patients.[A] 

4. Enter medication allergy lists or indicate no known medication 
allergies for more than 80 percent of patients.[A] 

5. Enable the EHR system's ability to check a prescription for 
potential drug-drug and drug-allergy interactions.[A] 

6. Record as structured data demographics for more than 50 percent of 
patients. 

7. Record as structured data list of current and active diagnoses or 
indicate no known problems for more than 80 percent of patients. 

8. Record as structured data height, weight, and blood pressure for 
more than 50 percent of patients aged 2 and over. 

9. Record as structured data smoking status for more than 50 percent 
of patients aged 13 and over. 

10. Implement one clinical decision support rule relevant to specialty 
or high clinical priority. 

11. Report ambulatory clinical quality measures to the Centers for 
Medicare & Medicaid Services (CMS) or the states.[B] 

12. Provide electronic copy of health information within 3 business 
days to more than 50 percent of all patients who requested that 
information. 

13. Provide clinical summaries to patients within 3 business days for 
more than 50 percent of all office visits. 

14. Perform at least one test of certified EHR technology's capacity 
to electronically exchange key clinical information (i.e., problem 
list, medication list, medication allergies, or diagnostic test 
results). 

15. Protect electronic health information created or maintained by the 
certified EHR technology by conducting or reviewing a security risk 
analysis, implementing security updates as necessary, and correcting 
identified security deficiencies. 

Additional requirements: 

1. Perform medication reconciliation for more than 50 percent of all 
transitions of care.[A] 

2. Enable the EHR system's ability to check a prescription against a 
formulary and maintain access to at least one internal or external 
drug formulary for the entire EHR reporting period.[A] 

3. Incorporate as structured data more than 40 percent of all clinical 
lab tests results ordered. 

4. Generate at least one list of patients by a specific condition. 

5. Send reminders during the EHR reporting period for preventative or 
follow-up care to more than 20 percent of patients aged 65 and over or 
aged 5 and younger. 

6. Provide electronic access to health information within 4 business 
days of being updated in the EHR system to more than 10 percent of 
patients. 

7. Provide patient-specific education resources to more than 10 
percent of all patients. 

8. Provide summary of care record to more than 50 percent of 
transitions of care and referrals. 

9. Perform at least one test of certified EHR technology's capacity to 
submit electronic data to immunization registries and follow-up 
submission if the test is successful.[C] 

10. Perform at least one test of certified EHR technology's capacity 
to provide electronic syndromic surveillance data to public health 
agencies and follow-up submission if the test is successful.[C]. 

Source: GAO analysis of CMS regulation. 

Note: Unless a provider has an exception for all of the public health- 
related reporting requirements, the provider must report at least one 
of the public health-related reporting requirements among the five 
additional requirements that the provider reports. 

[A] The requirement is electronic prescribing-related. 

[B] According to CMS, clinical quality measures help quantify health 
care processes, outcomes, patient perceptions, and organizational 
structure. To meet this reporting requirement, providers must report 
on 6 out of 44 clinical quality measures identified by CMS. 

[C] The requirement is public health-related. 

[End of table] 

[End of section] 

Appendix VI: Comments from the Department of Health and Human Services: 

Department Of Health & Human Services: 
Office Of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

January 24, 2011: 

Linda T. Kohn: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, DC 20548: 

Dear Ms. Kohn: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) draft report entitled: "Electronic Prescribing: CMS Should 
Address Inconsistencies in Its Two Incentive Programs That Encourage 
the Use of Health Information Technology" (GA0-11-159). 

The Department appreciates the opportunity to review this report 
before its publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

[End of letter] 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office'S (GAO) Draft Report Entitled, 
"Electronic Prescribing: CMS Should Address Inconsistencies In Its Two 
Incentive Programs That Encourage The Use Of Health Information 
Technology" (GAO-11-159): 

The Department appreciates the opportunity to review and comment on 
this draft report. GAO was asked to examine the Electronic Prescribing 
(eRx) Incentive Program that was authorized by the Medicare 
Improvements for Patients and Providers Act of 2008. GAO examined how 
the Centers for Medicare & Medicaid Services (CMS) determines which 
providers receive incentive payments and avoid payment adjustments 
from the eRx Incentive Program and how many providers received 
incentive payments in 2009. GAO also examined how the requirements of 
the eRx Incentive Program compares with the requirements of the 
Medicare and Medicaid Electronic Health Records (EHR) Incentive 
Program authorized by the Health Information Technology for Economic 
and Clinical Health Act of 2009. 

Below are the recommendations for executive action made by GAO and 
CMS' responses to them. 

GAO Recommendations: 

To help improve the effectiveness of the Electronic Prescribing and 
EHR Programs to encourage the adoption of health information 
technologies among Medicare providers, the Administrator of CMS should 
take the following three actions: 

* Direct physicians and other health care providers in the Electronic 
Incentive Program to use electronic prescribing technology that has 
been certified as an EHR system or an EHR module(s) for use in the EHR 
Incentive Program. 

* Expedite efforts to remove the overlap in reporting requirements for 
physicians who may be eligible for incentive payments or subject to 
penalties under both the Electronic Prescribing and EHR Programs by, 
for example, aligning the reporting requirements so that successfully 
qualifying for incentive payments or for avoiding penalties under the 
EHR program would likewise result in meeting the requirements for the 
Electronic Prescribing Program. 

* Identify factors that helped or hindered implementation of the 
Electronic Prescribing Program to help support the ongoing 
implementation of the EHR Program. CMS could include consideration of 
such factors in the integration plan that the agency is required to 
develop by January 1, 2012. 

To help ensure that the Electronic Prescribing Program resources are 
used appropriately, the Administrator of CMS should develop a risk-
based strategy to audit a sample of providers who received incentive 
payments from the Electronic Prescribing Program to help ensure that 
providers who receive incentive payments meet that program's 
requirements. A risk-based strategy could, for example, focus on those 
providers who received large incentive payments. 

CMS Response to Recommendation 1: 

* Direct physicians and other health care providers in the Electronic 
Incentive Program to use electronic prescribing technology that has 
been certified as an EHR system or an EHR module(s) for use in the EHR 
Incentive Program. 

We concur with the recommendation in that we agree with the notion 
that eligible professionals should be able to use certified EHR 
systems for the eRx Incentive Program. We do not, however, agree that 
CMS should direct eligible professionals to use only prescribing 
technology that has been certified as an EHR system. 

As pointed out in the report, the eRx Incentive Program began prior to 
the enactment of the EHR Incentive Program and, thus, before the 
availability of a Department of Health and Human Services (HHS) 
administered certification process for EHR technology. As a result, 
the eRx Incentive Program was based on the use of a "qualified" eRx 
system with specific defined functionalities, as defined in the 
electronic prescribing quality measure currently used for the eRx 
Incentive Program. In addition, more health care providers are 
eligible for the eRx Incentive Program than for the EHR Incentive 
Program. Therefore, eligible professionals that implemented 
"qualified" eRx systems in accordance with the current eRx Incentive 
Program requirements may not have gone through the more recent EHR 
certification process. We believe that additional rulemaking would be 
needed to direct eligible professionals that only certified EHR 
technology would meet requirements for the eRx Incentive Program. Such 
direction may also add to the cost and burden for existing eRx 
Incentive Program participants by potentially requiring professionals 
to replace existing qualified electronic prescribing systems (for 
example, stand-alone electronic prescribing systems that do not meet 
current Office of the National Coordinator (ONC) certification 
requirements for the EHR Incentive Program) merely to continue to 
participate in the eRx Incentive Program. 

CMS Response to Recommendation 2: 

* Expedite efforts to remove the overlap in reporting requirements for 
physicians who may be eligible for incentive payments or subject to 
penalties under both the Electronic Prescribing and EHR Programs by, 
for example, aligning the reporting requirements so that successfully 
qualifying for incentive payments or for avoiding penalties under the 
EHR program would likewise result in meeting the requirements for the 
Electronic Prescribing Program. 

We agree and are working actively to better align the reporting 
requirements for the two programs, where applicable. As required by 
the Affordable Care Act, CMS is required to develop a plan to 
integrate reporting on the EHR Incentive Program with reporting on the 
Physician Quality Reporting System by January 1, 2012. We plan to 
discuss this plan for better alignment in our rulemaking for the 2012 
program year during 2011. Section 1848(m)(3)(B) of the Social Security 
Act (the Act) sets forth the requirements for a successful electronic 
prescriber, and the standard currently adopted under the eRx Incentive 
Program requires the submission of data on an electronic prescribing 
measure established under the Physician Quality Reporting System. 
Currently, the electronic prescribing measure that eligible 
professionals are required to report under the eRx Incentive Program 
is different from the electronic prescribing requirements of the EHR 
Incentive Program and from the quality measures required under the EHR 
Incentive Program. Given how both programs are currently structured 
and the statutory construct of each program, CMS would need to undergo 
further rulemaking in order to implement changes to better align the 
reporting requirements under the 2 programs, where applicable. In the 
meantime, we plan to conduct extensive education and outreach 
activities regarding the eRx Incentive Program and the need to 
participate in this program independent of the EHR Incentive Program 
despite the prohibition under section 1848(m)(2)(D) of the Act on 
duplicate payments under both programs. 

CMS Response to Recommendation 3: 

* Identify factors that helped or hindered implementation of the 
Electronic Prescribing Program to help support the ongoing 
implementation of the EHR Program. CMS could include consideration of 
such factors in the integration plan that the agency is required to 
develop by January I, 2012. 

CMS believes this is a helpful recommendation. We have begun to look 
into this through comments received on the calendar year 2011 Medicare 
Physician Fee Schedule proposed rule. Some factors that we believe 
have helped implementation are: 

* Revising the reporting requirement for being a successful electronic 
prescriber from reporting on 50 percent of applicable cases to 
reporting on 25 unique electronic prescribing events beginning in 2010; 

* Adding registry and FUR reporting mechanisms and the group practice 
reporting option in 2010; and; 

* Adding codes to the electronic prescribing measure's denominator in 
2010 that expanded opportunities to report the electronic prescribing 
measure. 

Some commenters expressed challenges that they have encountered in 
implementing electronic prescribing technology and/or participating in 
the eRx Incentive Program. CMS has identified some potential issues 
that eligible professionals have expressed (both via comments to our 
proposed rule and during educational presentations which have 
occurred). Some of these issues include: 

a) The cost of purchasing and implementing electronic prescribing 
systems (provider training, potential disruption to workflow, etc.); 

b) The pending EHR Incentive Program. Some eligible professionals have 
stated that they want to purchase a comprehensive EHR program and, 
accordingly, have delayed purchasing and implementing their EHR (and, 
therefore, their eRx component). They may be waiting for 2011 and the 
first year of the EHR Incentive Program; 

c) The difficulty of electronically prescribing narcotics and other 
controlled substances. Some eligible professionals only prescribe 
narcotics or other controlled substances. While the Drug Enforcement 
Agency recently has allowed controlled substances to be electronically 
prescribed, not all States have adopted this policy. Additionally, 
electronically prescribing controlled substances requires an 
electronic prescribing system that has capabilities beyond what is 
currently required by the eRx Incentive Program measure, and these 
systems are not readily available commercially. 

d) The need for an electronic prescribing event to be associated with 
an eligible encounter in the office or nursing home. Some eligible 
professionals have suggested that refills or electronic prescriptions 
generated in response to a phone call from the patient should be 
counted. This information may be difficult to collect. 

Section 1848(m)(3)(B)(iii) of the Act also permits CMS to determine 
whether an eligible professional is a successful electronic prescriber 
based on the electronic submission of a sufficient number of 
prescriptions under Part D during the reporting period. We are 
continuing to explore the feasibility of using Part D prescription 
drug event (PDE) data to capture electronic prescribing events instead 
of requiring eligible professionals to report an electronic 
prescribing measure. There has been some concern about the accuracy 
and completeness of the PDE data with respect to whether a 
prescription was submitted electronically and with respect to the 
National Provider Identifier data that is submitted with the PDE. 

CMS Response to Recommendation 4: 

To help ensure that the Electronic Prescribing Program resources are 
used appropriately, the Administrator of CMS should develop a risk-
based strategy to audit a sample of providers who received incentive 
payments from the Electronic Prescribing Program to help ensure that 
providers who receive incentive payments meet that program's 
requirements. A risk-based strategy could, for example, focus on those 
providers who received large incentive payments. 

We agree that an audit of a sample of eligible professionals who 
received incentive payments may be needed, but disagree that it should 
necessarily focus on eligible professionals who received large 
incentive payments. As the eRx Incentive Program requires 25 
electronic prescribing instances to be reported for purposes of 
qualifying for an incentive (regardless of the amount of the incentive 
received), we believe that the audit process, if implemented, could be 
completely random. In fact, practices who receive smaller incentive 
payments may have fewer Medicare encounters (as is evidenced by their 
smaller incentive) which may make it more difficult to reach the 25 
electronic prescribing events as required by the program. 
Additionally, the option of using Part D prescription drug event data 
in lieu of reporting on the electronic prescribing measure to 
determine successful electronic prescribing may alleviate the need for 
an audit. 

We appreciate the efforts that went into this report and look forward 
to working with the GAO on this and other issues. 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Linda T. Kohn, (202) 512-7114 or kohnl@gao.gov: 

Staff Acknowledgments: 

In addition to the contact name above, Robert Copeland, Assistant 
Director; Nick Bartine; George Bogart; Julianne Flowers; Krister 
Friday; Toni Harrison; Daniel Lee; Shannon Legeer; and Sarah Marshall 
made key contributions to this report. 

[End of section] 

Footnotes: 

[1] An electronic health record is a collection of information about 
the health of an individual or the care provided, including patient 
demographics, progress notes, problems, medications, vital signs, past 
medical history, immunizations, laboratory data, and radiology reports. 

[2] See, for example, American Medical Association, Comparison of 
Stand-Alone Versus EMR Systems, available at [hyperlink, 
http://www.ama-
assn.org/assets/eprescribing/downloadable_resources/standalone-versus-
emr.pdf] (accessed Dec. 9, 2010). 

[3] Not all providers that bill Medicare are eligible for incentive 
payments or penalties under both programs. According to CMS, almost 1 
million physicians and other nonphysician providers billed Medicare in 
2009. See CMS, Data Compendium, 2009 Edition, available at [hyper;inl, 
https://www.cms.gov/DATACOMPENDIUM/15_2009_DATA_COMPENDIUM.ASP], 
accessed on October 26, 2010. The types of providers eligible for 
incentive payments or penalties under the two programs are not 
identical. 

[4] Pub. L. No. 110-275, § 132(a), 122 Stat. 2494, 2527. 

[5] A qualified electronic prescribing system must have several 
technological capabilities, including the ability to perform the 
following: generate a complete medication list; generate and transmit 
prescriptions electronically, and conduct alerts; provide information 
on formulary or tiered formulary medications, patient eligibility, and 
authorization requirements; and provide information on lower-cost, 
therapeutically appropriate alternatives (if any). Additionally, a 
qualified electronic prescribing system must be consistent with CMS's 
Part D electronic prescribing standards. 

[6] Pub. L. No. 110-275, § 132(b), 122 Stat. 2529 (as amended by the 
American Recovery and Reinvestment Act of 2009 [Recovery Act], Pub. L. 
No. 111-5, § 4101(f), 123 Stat. 115, 476 [providing that payment 
adjustments end after 2014]). In this report we use the term "penalty" 
to denote a reduction in reimbursement to a non-compliant provider and 
not the assessment of a fine or civil money penalty. 

[7] Pub. L. No. 111-5, div. B, tit. IV, §4101(a), 123 Stat. 115, 467 
(div. A, tit. XIII and div. B, tit. IV of Pub. L. No. 111-5 may be 
cited as the Health Information Technology for Economic and Clinical 
Health Act (HITECH Act)). 

[8] In a general sense, Congress defined "meaningful use" in this 
context to mean that the user of health information technology 
demonstrates to the satisfaction of the Secretary of HHS that the 
technology is certified and being used in a meaningful manner, that 
the technology is connected in a manner that provides for the 
electronic exchange of health information to improve the quality of 
health care, and that such information is submitted in a form and 
manner specified by the Secretary. See Pub. L. No. 111-5, § 4101(a) 
123 Stat. 467, 469-470. 

[9] The HITECH Act also established incentive programs for eligible 
providers participating in Medicaid, Medicare Advantage organizations--
private companies that provide Medicare health insurance coverage to 
beneficiaries for hospital, physician, and other services--and 
hospitals that participate in Medicare or Medicaid and that adopt and 
meaningfully use EHR technology. These programs are outside the scope 
of this report. See Pub. L. No. 111-5, §§ 4101, 4102, 4201, 123 Stat. 
467, 477, 489. 

[10] Pub. L. No. 111-5, § 4101(b), 123 Stat. 472. 

[11] Pub. L. No. 110-275, § 132(c), 1223 Stat. 2530. 

[12] See Medicare Program; Payment Policies Under the Physician Fee 
Schedule and Other Revisions to Part B for CY 2009, preamble II.O2., 
73 Fed. Reg. 69726, 69847 (Nov. 19, 2008) (program year 2009); 
Medicare Program; Payment Policies Under the Physician Fee Schedule 
and Other Revisions to Part B for CY 2010, preamble II.G.5., 74 Fed. 
Reg. 61738, 61849 (Nov. 25, 2009) (program year 2010); and Medicare 
Program; Payment Policies Under the Physician Fee Schedule and Other 
Revisions to Part B for CY 2011, preamble VII.F.2, 75 Fed. Reg. 73170, 
73551 (Nov. 29, 2010) (program year 2011). 

[13] See Establishment of the Temporary Certification Program for 
Health Information Technology, 75 Fed. Reg. 36158 (June 24, 2010) 
(temporary certification provisions to be codified at 45 C.F.R. part 
170); Medicare and Medicaid Programs; Electronic Health Record 
Incentive Program, 75 Fed. Reg. 44314 (July 28, 2010) (standards and 
certifications provisions to be codified at 42 C.F.R. part 495), and 
Health Information Technology: Initial Set of Standards, 
Implementation Specifications, and Certification Criteria for 
Electronic Health Record Technology, 75 Fed. Reg. 44590 (July 28, 
2010) (certification provisions to be codified at 45 C.F.R. part 170). 

[14] As of the date of this report, the most recent complete-year data 
available for the Electronic Prescribing Program were for 2009. 

[15] We did not independently review these studies or the electronic 
prescribing technologies referenced in them; their inclusion is not 
intended to endorse the methods, practices, or technologies used. 

[16] A formulary is a list of generic and brand name prescription 
drugs, grouped by therapeutic class. 

[17] Chiropractors are eligible providers in the EHR Program, but 
because they do not have prescribing authority, they are not able to 
obtain incentive payments and are not subject to penalties from the 
Electronic Prescribing Program. 

[18] Medicare Part B pays for physician, outpatient hospital, home 
health care, and certain other services. 

[19] Pub. L. No. 111-5, §4101(f)(2), 123 Stat. 477. 

[20] Providers cannot receive incentive payments from the Electronic 
Prescribing Program the same year they receive incentive payments from 
the Medicare EHR Program. Providers that are eligible for both the 
Medicare and Medicaid EHR Programs must choose the program from which 
they will receive incentive payments. Until 2015, providers eligible 
for both the Medicare and Medicaid EHR Program may switch programs 
only once after the first incentive payment is initiated. If those 
providers are eligible for and receive incentive payments from the 
Medicaid EHR Program they are also permitted to receive incentive 
payments from the Electronic Prescribing Program. 

[21] On a case-by-case basis, CMS may exempt certain providers from 
penalties assessed by either the Electronic Prescribing or EHR 
Programs if it determines that complying with each program's reporting 
requirements would result in a significant hardship to the provider. 
See 42 U.S.C. §§ 1395w-4(a)(5)(B) (Electronic Prescribing Program), 
(7)(B) (EHR Program). 

[22] If CMS finds that less than 75 percent of providers meet the EHR 
Program's requirements, CMS may increase the penalty percentage in the 
EHR Program beginning in 2018 by up to 1 percent per year, with a 
maximum penalty of 5 percent. See 42 U.S.C. §§ 1395w-4(a)(7)(A)(iii). 

[23] In technical comments provided on a draft of this report, HHS 
stated that this provision of the EHR Program promotes participation 
in the Electronic Prescribing Program. 

[24] The Electronic Prescribing Program will assess penalties 
prospectively--that is, concurrently with claims submissions. A CMS 
official told us that the agency has not yet determined how it will 
assess penalties in the EHR Program. Similar to the Electronic 
Prescribing Program, CMS could assess penalties for the EHR Program 
concurrently with claims submission. 

[25] A provider who earns at least $24,000 in total allowed Medicare 
Part B charges in 2011 or 2012 and earns incentive payments from the 
EHR program in 2011 or 2012 will earn the maximum payments from that 
program, because the annual incentive payment amount is equal to 75 
percent of the allowed charges, up to the annual limits displayed in 
appendix IV. 

[26] For providers who first obtain incentive payments from the EHR 
Program in 2011, 2012, or 2013, the stage-one reporting requirements 
will apply to their first 2 years of participation. For providers who 
first obtain incentive payments from the EHR Program in 2014, the 
stage-one reporting requirements will apply only to the first year of 
participation. The years in which stage-two requirements will apply 
for providers will depend on the first year they obtain incentive 
payments. CMS has not yet determined what stages will apply to 
providers for years 2015 and beyond. 

[27] See 75 Fed. Reg. 44321. 

[28] To obtain incentive payments from the EHR Program in 2011, 
providers must meet or exceed the reporting requirements in a 
continuous 90-day period. After 2011, eligible providers must meet or 
exceed the reporting requirements over a full year. 

[29] Certain providers may be exempted from reporting requirements 
that fall outside the scopes of their practices. 

[30] Clinical decision support can include checks for allergies, drug- 
drug interactions, overly high doses, and clinical conditions, as well 
as other patient-specific dose checking. 

[31] Pub. L. No. 111-148, § 3002, 124 Stat. 363. 

[32] PQRS, formerly known as the Physician Quality Reporting 
Initiative or PQRI, was established by the Tax Relief and Health Care 
Act of 2006 (Pub. L. No. 109-432, div. B, § 101(b), 120 Stat. 2922, 
2975) as modified by MIPPA (Pub. L. No. 110-275, § 131(b), 122 Stat. 
2521) and the Patient Protection and Affordable Care Act of 2010 (Pub. 
L. No. 110-148, § 3002, 124 Stat. 363). Through PQRS, incentive 
payments are available to physicians and other eligible providers 
through 2014, and penalties will be assessed on providers that do not 
report any quality measures after 2014. In a given year, providers may 
obtain incentive payments from PQRS in addition to either the 
Electronic Prescribing Program or the EHR Program. 

[33] Congress directed CMS to use electronic prescribing quality 
measures established for PQRS in 2008 to determine which eligible 
providers would receive incentive payments for the Electronic 
Prescribing Program in 2009. Pub. L. No. 110-275 §132, 122 Stat. 2527 
(adding SSA § 1848(m) (3)(B)(ii)). After Congress established the 
Electronic Prescribing Program, the electronic prescribing measure was 
removed from PQRS. The Electronic Prescribing Program and PQRS have 
other similarities. For example, the types of providers eligible for 
both programs are identical. However, eligibility for the Electronic 
Prescribing Program is further restricted to providers that have 
prescribing authority. 

[34] Providers reported the electronic prescribing codes on the claims 
they submitted for reimbursement for the services performed during the 
applicable patient visit. An applicable patient visit is any patient 
visit identified by certain services included on a provider's Part B 
claims. For 2009, CMS designated 33 services as applicable visits for 
the Electronic Prescribing Program, which were typically services 
provided in the office or outpatient settings. 

[35] Beginning on June 1, 2010, the Drug Enforcement Administration 
first authorized the electronic prescription of certain controlled 
substances. See Electronic Prescriptions for Controlled Substances, 75 
Fed. Reg. 16236 (Mar. 31, 2010) (to be codified in various sections at 
21 C.F.R. parts 1300, 1304, 1306 and 1311). Prior to this date, such 
authority did not exist. 

[36] CMS made this determination in 2010. 

[37] Because providers can belong to multiple unrelated health care 
practices, CMS determined which providers met or exceeded the 
reporting requirement using each unique combination of providers' 
national provider identifier numbers--a unique number that identifies 
each provider--and tax identification numbers--a unique number that 
identifies each entity that bills CMS for Medicare reimbursements on 
behalf of the provider. If the unique combination of national provider 
identifier and tax identification number met the reporting 
requirement, to calculate the incentive payment, CMS multiplied the 
total allowed Medicare Part B charges for the year for that national 
provider identifier and tax identification number combination by 2 
percent. CMS made the payment to the practice represented by the tax 
identification number associated with the provider. 

[38] CMS included the adjustment factor--1.036 percent--to account for 
claims submitted by providers for 2009 that were not final at the time 
the agency determined the incentive payment amounts. 

[39] CMS made some modifications to the list of services designated as 
applicable visits for 2010, for a total of 56 services. For example, 
compared to the services designated as applicable visits, beginning in 
2010, CMS added services that occur in a nursing home or home care 
setting. As a result, more providers may meet the 10 percent 
participation threshold in 2010 than would have in 2009, which may 
increase the number of providers that receive the incentive payment in 
those years. 

[40] In 2010, providers were not permitted to report the electronic 
prescribing code if the electronic prescribing system transmitted the 
prescription by fax. However, providers were permitted to report the 
electronic prescribing code if the provider's electronic prescribing 
system transmits the prescription to the pharmacy electronically, but 
the pharmacy network converts the electronic prescription into a fax 
because the pharmacy cannot receive electronic prescription 
transmittals. 

[41] To participate in the Electronic Prescribing Program as a group 
practice, the practice must also participate in CMS's PQRS as a group 
practice. For 2010, 27 group practices notified CMS that they would 
participate in the Electronic Prescribing Program under the group 
practice reporting option. If CMS determines that a group practice 
will receive an incentive payment, the agency determines the incentive 
payment amount based upon the total allowed Medicare Part B charges 
for the year for all providers in the group practice even if some 
providers in the group did not submit the electronic prescribing 
reporting code during the year. 

[42] The two alternative reporting mechanisms available in 2010 were 
certain registries or EHR systems. A registry is an organization 
identified by CMS that collects the electronic prescribing reporting 
codes from providers and submits aggregated information to CMS. CMS 
approved certain EHR systems for the Electronic Prescribing Program 
and those systems are not necessarily systems certified for use in 
CMS's EHR Program. For 2010, CMS approved 40 registries as 
organizations able to submit the electronic prescribing code and seven 
EHR vendors with products that providers could use to submit the 
electronic prescribing code. In technical comments provided on a draft 
of this report, HHS noted that these two reporting mechanisms were 
significant additions to the program. However, at the time of our 
work, it was unclear how many providers would use these alternative 
reporting mechanisms for the 2010 period because providers were not 
required to notify CMS in advance of their intention to use either 
mechanism. 

[43] See 75 Fed. Reg. 73551. 

[44] Group practices of 2-10 providers must report the electronic 
prescribing code for at least 75 applicable visits; 11-25 providers 
must report the code for at least 225 applicable visits; 26-50 
providers must report the code for at least 475 applicable visits; 51- 
100 providers must report the code for at least 925 applicable visits; 
and 101-199 providers must report the code for at least 1,875 
applicable visits. 

[45] CMS has noted that the data collection period would help the 
agency make the determination of whether the penalty applies in 
advance of 2012 in order to apply the penalty in 2012 concurrently 
with claims submission. See 75 Fed. Reg. 40208. 

[46] Although CMS allowed individual providers and group practices to 
report the electronic prescribing code through one of two alternatives 
to Part B claims--that is, a registry or certain EHR systems--to 
obtain incentive payments in 2010 and 2011, CMS will not analyze 
electronic prescribing code submissions reported through these 
alternative mechanisms to determine which providers will be subject to 
penalties in 2012. 

[47] CMS will not apply the penalty to individual providers if they 
meet one of the following criteria during the reporting period: (a) 
are not physicians, nurse practitioners, or physician assistants and 
therefore generally do not have prescribing authority; (b) have less 
than 100 applicable visits; or (c) have less than 10 percent of their 
total allowed Medicare Part B charges from the services designated as 
applicable visits. 

[48] See 75 Fed. Reg. 73551. 

[49] CMS will not apply the penalty to group practices that have less 
than 10 percent of their total allowed Medicare Part B charges from 
the services designated as applicable visits. 

[50] See 75 Fed. Reg. 73563. 

[51] If CMS takes the same approach to establish the requirements 
providers must meet to avoid penalties in 2013 and 2014 as the agency 
took to avoid penalties in 2012, CMS will propose requirements 
providers must meet to avoid penalties in 2013 in July 2011 and 
finalize the requirements in November 2011, and will propose 
requirements providers must meet to avoid penalties in 2014 in July 
2012 and finalize the requirements in November 2012. 

[52] See 75 Fed. Reg. 73565. 

[53] CMS contracts with private companies--such as health insurance 
companies and companies that manage pharmacy benefits--to provide 
prescription drug benefits to Medicare beneficiaries. These companies 
are referred to as Part D plan sponsors. 

[54] Since April 1, 2009, prescription drug plan sponsors were 
required to submit Part D claims with the individual provider's 
national provider identifier included, if available. Since January 1, 
2010, pharmacies have submitted a data field--called the prescription 
origin code--on Part D claims for new prescriptions that indicates 
whether the prescription was received by the pharmacy electronically, 
by facsimile, by telephone, or in hardcopy. CMS required prescription 
drug plan sponsors to submit the origin code on the Part D claim and 
the drug plan sponsors are requiring that the pharmacies in their 
network complete that data field. 

[55] In technical comments provided on a draft of this report, HHS 
noted that if CMS used Part D data instead of the electronic 
prescribing reporting codes, CMS would not be able to determine 
whether the electronic prescribing system used by the provider met the 
capabilities of a qualified electronic prescribing system. 

[56] While CMS determined which providers met or exceeded the 
reporting requirement using each unique combination of providers' 
national provider identifier numbers and tax identification numbers, 
we analyzed 2009 Electronic Prescribing Program participation at the 
national provider identifier level only so that we could present 
results for unduplicated providers. The number 597,000 represents a 
count of all Medicare providers who had at least one applicable visit 
in 2009. However, not all of these providers have prescribing 
authority. Consequently, there may be some individuals included in the 
count of 597,000 providers that were not eligible for an electronic 
prescribing incentive payment. 

[57] The number of providers that received incentive payments from CMS 
for the 2009 Electronic Prescribing Program differs from an estimate 
made by Surescripts, a company that operates a network connecting 
providers, pharmacists, and patients by electronically routing 
prescriptions, providing electronic access to patient benefit and 
formulary information, and providing electronic access to patients' 
medication histories. Surescripts reported in September 2010 that more 
than 200,000 office-based providers (physicians, nurse practitioners, 
and physician assistants) had transmitted prescriptions 
electronically. One possible reason for the difference is that the 
Surescripts estimate counts any provider who transmitted at least one 
prescription electronically in a 30-day period whereas CMS's estimate 
is based on both elements of the 2009 reporting requirement. See 
Surescripts, "1 In 3 Prescriptions Are Now E-Prescriptions in 
Massachusetts as Number of E-Prescribing Physicians Grows to 200,000 
Nationwide," press release (Sept. 21, 2010). Downloaded on September 
21, 2010, from [hyperlink, 
http://www.surescripts.com/media/683832/092110_safe_rx_final_release_quo
te.pdf]. 

[58] Buccaneer, PQRI 2009 Electronic Prescribing (eRx) Final Program 
Monitoring and Evaluation Report (Oct. 22, 2010). In contrast to the 
way we determined provider, this report determined provider at the 
national provider identifier and the taxpayer identification number 
basis. 

[59] In 2009, about 66 percent of the time that the three electronic 
prescribing reporting codes were submitted, the provider included the 
one code indicating that no prescriptions were generated during the 
visit. 

[60] ONC reports to the Secretary of HHS and plays a role in the EHR 
Program by establishing the standards and specifications that 
providers' systems must meet for the EHR Program, coordinating with 
CMS on the development of the meaningful use criteria, and creating 
and administering the certification program that authorizes third-
party organizations to certify EHR technology. As of November 2010, 
these third-party organizations had certified 73 EHR products. The 
following committees contributed to the establishment of the standards 
and specifications for the EHR Program: the American Health 
Information Community, the Certification Commission for Health 
Information Technology, the Health Information Technology Standards 
Panel, and the HIT Policy and Standards Committees. 

[61] Office of the National Coordinator for Health Information 
Technology, "Temporary Certification Program," Available at 
[hyperlink, 
http://healthit.hhs.gov/portal/server.pt?open=512&objID=2885&parentname=
CommunityPage&parentid=72&mode=2&in_hi_userid=12059&cached=true] 
(accessed Dec. 13, 2010). 

[62] In April 2010, the Health IT Policy Committee, a federal advisory 
committee that advises ONC on health IT policy issues, made several 
recommendations to HHS on the topic of patient safety, including 
recommendations related to the EHR certification criteria. The 
committee recommended that the EHR certification criteria require 
software vendors to maintain records on all patient safety concerns 
reported by their customers and that vendors establish processes to 
promptly provide all affected customers with safety alerts. 

[63] Office of the National Coordinator for Health Information 
Technology, "Standards & Certification Criteria Final Rule," Available 
at [hyperlink, 
http://healthit.hhs.gov/portal/server.pt?open=512&objID=1195&parentname=
CommunityPage&parentid=97&mode=2&in_hi_userid=11673&cached=true] 
(accessed Dec. 13, 2010). 

[64] Providers seeking incentive payments from the EHR Program must 
also report the name of the EHR system they are using to CMS. 

[65] All modules certified for use in the EHR Program must meet all 
privacy and security standards established by ONC. 

[66] Under the EHR Program, certified EHR technology must also be able 
to support medication reconciliation, however, this is not a 
technological requirement for the Electronic Prescribing Program. 

[67] See 75 Fed. Reg. 73556. 

[68] A CMS official in the Office of Clinical Standards and Quality, 
which administers the Electronic Prescribing Program, told us that CMS 
did not have the resources to develop a certification process for the 
Electronic Prescribing Program. CMS does not collect information on 
which electronic prescribing systems providers are using. 

[69] In technical comments provided on a draft of this report, HHS 
noted that, with the assistance of their electronic prescribing 
system's vendor, providers should be able to determine whether their 
electronic prescribing system contains the technical capabilities of a 
qualified system. While this is an option for providers, it may be 
unnecessary, given the existence of the list of certified EHR systems 
and certified EHR modules on ONC's Web site. 

[70] Providers wanting to obtain incentive payments for the EHR 
Program will have to meet a total of 20 reporting requirements, which 
include five mandatory and up to two additional reporting requirements 
related to electronic prescribing. 

[71] For the Electronic Prescribing Program, when providers report the 
electronic prescribing code, they are attesting that they used a 
qualified electronic prescribing system, which has the technological 
capabilities listed in figure 8. 

[72] Recent studies have shown that not all providers who adopt 
electronic prescribing systems routinely use all of the technological 
capabilities those systems provide, which may result in missed 
opportunities to improve quality and control costs. For example, a 
2010 study reported that fewer than 60 percent of physicians surveyed 
had access to three advanced electronic prescribing features, and less 
than a quarter routinely used all three features. See J.M. Grossman, 
"Even When Physicians Adopt E-Prescribing, Use of Advanced Features 
Lags," Center for Studying Health System Change, Issue Brief, no. 133 
(2010): 1-5. 

[73] For example, a physician with $24,000 in Medicare Part B 
allowable charges in 2011 would receive an $18,000 incentive payment 
under the EHR Program compared to a $240 incentive payment under the 
Electronic Prescribing Program. (See figure 3.) About 1 percent of the 
providers who earned incentive payments from the Electronic 
Prescribing Program in 2009 earned more than $18,000. 

[74] CMS will determine if providers should receive a penalty in 2012 
from the Electronic Prescribing Program based on whether or not the 
provider met certain reporting requirements in 2011. 

[75] Certain physicians that do not prescribe or do so infrequently 
will not be subjected to penalties, regardless of whether or not they 
meet the Electronic Prescribing Program's reporting requirement. 

[76] See 75 Fed. Reg. 73561. 

[77] HHS added that one option that may be considered is using Part D 
data, which would alleviate the need for providers to report to the 
Electronic Prescribing Program to avoid penalties from that program. 
However, as we have reported, CMS officials have raised several 
concerns--concerns echoed by the agency in comments made on our draft 
report--about the reliability of Part D data to determine which 
providers should receive incentive payments. CMS officials told us 
that these data reliability concerns should be resolved before Part D 
data can be used to determine which providers should receive incentive 
payments under the Electronic Prescribing Program. 

[78] See 75 Fed. Reg. 44324. 

[79] In addition, the HHS Office of Inspector General has the 
authority to conduct audits and investigations of HHS-regulated 
entities. See 5 U.S.C. app. 3. However, Inspectors General may not 
carry out program operating responsibilities. See 5 U.S.C. app. 3, § 
9(a). 

[80] We did not independently review these studies or the electronic 
prescribing technologies referenced in them; their inclusion is not 
intended to endorse the methods, practices, or technologies used. 

[81] Pub. L. No. 110-275, § 132(c), 1223 Stat. 2530. 

[82] To select a nongeneralizable sample of four organizations, we 
first conducted internet research to identify organizations that 
appeared to have measured the effect of electronic prescribing 
implementation on quality, cost, or both. Through this process, we 
identified five types of organizations that appeared to have measured 
the effects: state Medicaid programs, health insurance companies, 
pharmacy benefit managers, collaborative groups, and state employee 
benefit plans. In selecting our nongeneralizable sample, we identified 
organizations that represented four of the five types of organizations 
that appeared to have measured the effects. Through this process, we 
confirmed that the organizations that we sampled had indeed measured 
the effects of electronic prescribing on quality, cost, or both. 

[83] To identify these articles, we conducted a literature search of 
articles published from January 1, 2005, to May 14, 2010, and 
supplemented that search with articles that we identified during the 
course of our work. We limited our review to studies conducted in the 
United States. 

[84] The studies we reviewed may have reported outcomes and findings 
not summarized in this appendix. 

[85] In tiered systems, insurers identify preferred medications, often 
generic medications, and designate them as Tier 1, with the lowest 
copayment. Tier 2 medications generally require a higher copayment, 
may include moderately priced brand-name medications. Tier 3 
medications are generally expensive brand-name medications for which 
generic alternatives are available in lower copayment tiers. 

[86] The national provider identifier number is a unique number that 
identifies each provider, and the tax identification number is a 
unique number that identifies each entity that bills CMS for Medicare 
reimbursements on behalf of the provider. Because providers can belong 
to multiple unrelated health care practices, CMS determined which 
providers met or exceeded the reporting requirement using each unique 
combination of providers' national provider identifier numbers and tax 
identification numbers. 

[87] We only obtained a count of the valid electronic prescribing code 
submissions. 

[88] Of the applicable providers that we were unable to match at the 
time of our analysis, CMS determined that 974 had national provider 
identifier numbers that had been deactivated and were therefore not 
available in the NPPES Downloadable File or the PECOS Global Extract 
file that we analyzed and another 77 had national provider identifier 
numbers that were not valid. 

[89] CMS determined that five providers from Puerto Rico and one 
provider from the Virgin Island obtained incentive payments. Providers 
from American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, 
and the Virgin Islands had at least one applicable visit. 

[End of section] 

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