e-Prescribing and
Electronic Health Record
Safe Harbor
Since the Federal
government wants to
ensure the secure
exchange of medical
information, it
advocates the adoption
of Health Information
Technology through
coordinated partnerships
between government
agencies and private
sector stakeholders. The
Federal Register, dated
August 8, 2006, titled,
"Medicare and State
Health Programs: Fraud
and Abuse; Safe Harbors
for Certain Electronic
Prescribing and
Electronic Health
Records Arrangements
Under the Anti-Kickback
Statute; Final Rule",
provides a safe harbor
for certain arrangements
involving the donation
of electronic
prescribing and
electronic health record
technology.
The following are some
of the variances noted
between eRx and EHR:
Who:
Donors -
eRx = Hospitals, Group
Practice, PDP sponsors,
and MA Organizations
EHR = (i) Individuals or
Entities (ii) Health
Plans
Recipients - Donors may
not select recipients
using any method that
takes into account
directly the volume or
value of referrals from
the recipient or other
business generated
between the parties.
What:
eRx = Hardware,
software, internet
connectivity, and
training and support
services
EHR = Software must
include eRx, be
interoperable, but can
not include Hardware
When:
Sunset Provision
eRx = None
EHR = 12/31/2013
How Much:
Value
eRx = No limit
EHR = Recipient must pay
15% of the donor's cost
[Note: The
aforementioned is not
meant to be a legal
interpretation of the
Safe Harbor. Instead, it
is a guideline for
various stakeholders,
donors, and recipients.
Please refer to legal
counsel for a definitive
position relating to
your health care
entity.]
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