Orthopedic Institute--SD

Document ID: CMS-2011-0108-0011
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: June 01 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 8 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 1 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 25 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e3951a
View Document:

This is comment on Proposed Rule

Medicare Program: Proposed Changes to Electronic Prescribing Incentive Program

View Comment

Please consider a hardship exemption for surgical practices such as orthopedics. A majority of the scripts that are written post-operatively cannot be attached to the correct billing code and therefore do not help meet the 10 script requirement per doctor. For example, the types of medications prescribed postoperatively (pain control, both narcotic and non-narcotic, anti-nausea medication, muscle relaxants, anti-coagulation drugs) cannot be determined until the end of the post-op course. The post-op circumstances will dictate which pain medication the patient can tolerate or which level of pain medication the patient needs, whether or not anti-nausea medication is needed, what type of anti-coagulation needs to be used, etc. If the scripts are written pre-operatively when the patient is in the office, the scripts may not be the correct ones to use, given the post-op course. This could result in extra cost to the patient and/or to the patient's drug plan.