November 10: We will discuss the question with CMS subject matter experts to determine the intent of Congress and any administrative challenges which might prevent inclusion of MA payments in the calculation of the E-prescribing bonus payment. December 1: Payment to physicians who have contracted with MA organizations generally are governed by the terms of the contract, and it is up to the MA organization whether to take eligibility for a PQRI bonus or e-prescribing incentive payment into account in establishing the amount the physician is paid. In the case of a private fee-for-service (PFFS) plan, however, if the MA organization offering the plan is meeting access requirements by paying what Medicare would pay, the MA organization is required to include bonus and incentive amounts if the physician would receive them in connection with treating a Medicare beneficiary not enrolled in an MA plan. Physicians who have not contracted with an MA organization, but provide covered services to an enrollee in an MA plan offered by the organization, are also potentially eligible for both the PQRI bonus payment and the e-prescribing incentive payment from the organization. When a physician is determined by Medicare to have satisfied the requirements and qualified for an incentive under the PQRI, he or she should expect to receive a bonus check from any MA organizations which he or she has billed as a non-contracted provider, or for which he or she has provided covered services under a PFFS plan that meets access standards by paying the Medicare payment rate. The amount of the PQRI payment is calculated just as it is calculated for traditional Medicare, that is to say a percentage (up to 1.5% for 2007 and 2008, and 2% for 2009 and 2010) of Medicare allowed charges for such covered professional services submitted to the plan during the reporting period. When a physician is determined by Medicare to be a successful e-prescriber and qualifies for the 2% incentive under the 2009 E-prescribing Incentive Program, MA plans are required to pay non-contracted physicians 2% of the Medicare allowed charges for any services rendered in 2009 to a member of that plan. This policy also applies to non-physician practitioners who would qualify for payments from traditional Medicare.
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