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Accelerating Adoption with New Ads, New Standards & New Requirements
by Tony Schueth,
Editor-in-Chief
Consumers are focus of new ad campaigns
In our last issue of HIT Perspectives, we
talked about the enormous investments in health information
technology (HIT) being made by both public and private stakeholders
to help consumers manage their health care. Recent developments are
again highlighting the roles consumers can play, this time in terms
of helping to drive adoption of ePrescribing. In other industries,
providers of goods and services dance to consumers' demands, so why
shouldn't they drive HIT?
Policy makers are
looking to consumer pressure to help drive ePrescribing in Medicare,
physician offices and in pharmacies. The Pharmaceutical Care
Management Association (PCMA), the association for pharmacy benefit
managers (PBMs), just launched a TV ad campaign to bolster its
lobbying efforts for making ePrescribing mandatory in Medicare Part
D. Called "Wake Up",the ad shows a widow in a barren cemetery
throwing flowers into an empty grave as bells toll. "It's time to
require ePrescribing in Medicare before more people die," the
voiceover intones. Aimed at both consumers and Congress, "This ad is
a wake up call to refocus the Medicare debate on patients, not just
the providers who serve them. From a patient's perspective, ePrescribing is by far the most important issue in the current
Medicare debate because it could save their life or the life of
someone they love," said PCMA President and CEO Mark Merritt in a
press release. You can see the ad on the PCMA Web site at
www.pcmanet.org.
SureScripts also is
looking to "patient power" to help promote ePrescribing adoption in
physician offices. Leveraging its base in the nation's chain
pharmacies and a growing number of independents, the company
recently launched a comprehensive consumer campaign. Through a media
relations effort, in-store signage and educational materials,
patients are being informed about the benefits of ePrescribing. For
example, they will soon begin seeing signs indicating "ePrescriptions
filled here" and "Give your prescription a head start" on the front
doors and counters of pharmacy locations nationwide. The campaign
points to a newly created Web site,
www.LearnAboutEprescriptions.com,
where they are encouraged to "push" their doctors to ePrescribe and
direct their physicians to the new online physician resource called
GetRxConnected.com, which was described in the last issue of HIT
Perspectives.
While many physicians
are still reticent to adopt ePrescribing, PCMA and SureScripts are
betting that the consumer voice can make a difference.
Driving ePrescribing through
standards adoption
Just about everyone has been
eagerly awaiting the new Centers for Medicare and Medicaid Services
(CMS) final rule adopting the latest batch of ePrescribing standards
for use in Medicare Part D. The rule was published April 7, 2008 in
the Federal Register and, as expected, stayed close to the
results of the 2006 Medicare Modernization Act (MMA) pilots. The
rule adopts NCPDP SCRIPT 8.1, prescription fill status notification,
and standards for formulary and benefit information and medication
history. It also requires use of the National Provider Identifier (NPI).
With the exception of the NPI requirement, the rule codifies
standards the industry has been using for the past several years. It
provides a firm, interoperable base for the millions of
ePrescriptions being sent every day through the secure
infrastructure already in place.
For some - particularly physicians - the rule does not go
far enough. The CMS final rule excludes three other standards that
were not judged ready for widespread industry use in the 2006 MMA
pilot: the RxNorm drug nomenclature, structured and codified "Sig,"
and a standard for electronic prior authorization (ePA)
transactions. Physician groups, particularly the American Medical
Association (AMA), would like the full suite of ePrescribing
standards adopted in 2009.
AMA lobbyists in April called for quick action on the
remaining three standards by the Department of Health and Human
Services (HHS). This was again underscored by a member of the AMA
board of trustees at the Brookings Institution's ePrescribing
meeting on May 10 in Washington. "Prescribers should be able to
efficiently transmit accurate and complete instructions for
medications being prescribed, use standard medication terminology,
and use real-time prior authorization," said Steven J. Stack, MD. "So, it really is essential that these three incomplete standards be
finalized and fully functional in order to realize the truly robust ePrescribing
benefits sought by so many."
We
are delighted to have the AMA on board with ePrescribing and
adopting the remaining standards. The availability of these
standards will help drive use of ePrescribing. As a result, both the
government and industry have been moving ahead on them. The Sig
standard should be ready to pilot this summer. RxNorm still has
holes remaining, which the National Library of Medicine (the
developer and manager of the standard) is aggressively working to
fill. The industry continues working on the ePA standard, and the
Agency for Healthcare Research and Quality (AHRQ) has retained
Point-of-Care Partners to help.
It is not clear when the next round of CMS rule
making will take place. From a timing standpoint, it is possible to
have rules for Sig and RxNorm in 2009, but ePA will take longer.
That said, if you're interested in ePA, there are things that you
can do in the interim. Give us a call or drop us an e-mail for more
on this subject.
Heads up on a new CMS requirement
The prescription claim (NCPDP Telecommunications 5.1) includes a
field for "prescription origin code," which indicates the source of
the prescription. At present, this code is optional and rarely and
inconsistently populated by pharmacies. However, CMS has identified
it as a means of monitoring ePrescribing utilization in Medicare
Part D. Details are in the 2009 Medicare Advantage (MA), Medicare
Advantage-Prescription Drug (MA-PD), Cost-Based Plan, and Stand
Alone Prescription Drug Plan (PDP) Call Letter. More information is
available on the CMS Web site at
www.cms.hhs.gov/PrescriptionDrugCovContra/01_Overview.asp.
Not
only could this be useful for CMS, it could have a much more
profound impact on other payers. If a claim could indicate that the
prescription was created or sent electronically, pharmacy benefit
managers (PBMs) could more easily - and on an ongoing basis -
calculate savings for their health plan clients. It also could help
health plans and others better calculate the return on investment
for ePrescribing, which can be difficult when ePrescriptions cannot
be matched to claims. In addition, the ability to identify a
prescription as electronic will be critically important in helping
physicians obtain their bonus payments if the E-MEDS bill passes
(described in the last HIT Perspective).
In a
recent meeting with CMS on behalf of a client, I pointed out how
much we support CMS mandating population of this field. In response,
CMS stressed how it is critical that MA-PDs and PDPs indicate how
important this field is in their formal response to the CMS 2009
Call Letter. Over the past few years, we have observed that CMS is
highly responsive to such feedback. Therefore, it stands to reason
that the more MA-PDs and PDPs indicating to CMS the importance of
mandating this field, the better.
We
recommend that you identify the person within your organization who
is responsible for responding to the CMS 2009 Call Letter and work
with him or her to make sure you comment on the importance of this
field. In our view, this is the only way this field will be
consistently populated.
Bits and Pieces
Health Evolution Partners has
invested in ePrescribing vendor Prematics, Inc. As part of the deal,
its chairman, David J. Brailer, MD, PhD, will join the
Prematics board of directors. Dr. Brailer, you may recall, was the
first director of the HHS Office of the National Coordinator for
Health Information Technology. " ... All participants at the
Brookings ePrescribing meeting on May 10" - including the AMA,
American Association of Retired Persons, Consumers Union, US Chamber
of Commerce and those representing the ePrescribing industry and
pharmacies - called for removal of the DEA prohibition on
ePrescribing of controlled substances. " ... Speaking of the DEA,
rumor has it that the long-awaited regulation will probably be
issued so that industry can take its best shots at whatever is
proposed. We understand that responses were to be quite specific
in terms of data on current industry privacy and security practices,
costs and benefits of the proposal, and combating fraud and abuse.
We will keep you posted. " ... Success stories of HIT adoption in
Minnesota were highlighted in an op-ed piece in the
Minneapolis Star-Tribune by former Speaker of the House Newt
Gingrich and Minnesota governor Tim Pawlenty. " ... The
National Governors' Association's e-Health Alliance adopted an ePrescribing call to action at its May 12 meeting in Washington.
" ... In response to
continuing interest in enforcement of the HIPAA Privacy Rule, the
HHS Office for Civil Rights (OCR) has added a new data section on
its Compliance and Enforcement Web site at
http://www.hhs....gov/ocr/privacy/enforcement/data.html. It
provides new information about several aspects of OCR's health
information enforcement program, including charts showing
state-specific case investigation results, calendar-year enforcement
results graphs and charts, calendar-year graph showing complaint
receipts, and yearly variation in the issues in cases resolved
through corrective action. " ...
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