National Committee on Vital and Health Statistics
Sub-Committee on Standards and Security

Draft Framework for Testifier Comments on the
Draft Criteria for
Selection of PMRI Standards

Good morning. My name is Lynne Gilbertson. I am Director of Standards Development for the National Council for Prescription Drug Programs (NCPDP).

NCPDP, located in Phoenix, AZ, is a not-for-profit ANSI-accredited Standards Development Organization consisting of 1300 members who represent computer companies, drug manufacturers, pharmacy chains and independents, drug wholesalers, insurers, mail order prescription drug companies, pharmaceutical claims processors, physician services organizations, prescription drug providers, software vendors, telecommunication vendors, service organizations, government agencies and other parties interested in electronic standardization within the pharmacy services sector of the health care industry.

1. Draft Criteria for Selection of PMRI Message Format Standards

NCPDP Response:

NCPDP has identified the need for a PMRI as it would apply to pharmacy business practices and transactions. Our goal is not to develop a new standard but to work with an existing standard from an ANSI SDO and if necessary request modifications to their standard to meet our needs, unless those needs could not be met.

For the past few years NCPDP members have been researching and reviewing potential standards that may meet our needs. Areas of interest to pharmacy include: sharing of prescription information with other health care providers (including pharmacies), allergies, lab results and diseases. NCPDP members believe that the HL7 standard is the best fit and our goal would be to work with HL7 to develop a standard implementation that would meet our needs and the needs of all Health Care providers.

We are currently looking very closely at an HL7 implementation being used by HealthNet in British Columbia. Healthnet has developed a Patient Profile standard that could be used as a resource to help develop NCPDP’s Patient Profile standard. Systems Xcellence, a software vendor in Canada and the U.S., has provided NCPDP with a copy of the Application Services Professional Pharmacy Services document, and the parts that were relevant to Patient Profile were reviewed within the NCPDP work group. The group’s goals are to decide on how the standard would take shape, whether it should be in HL7, NCPDP SCRIPT, NCPDP Telecommunication, or XML format, and to determine which parts of the HealthNet work would be most valuable. The group hopes to have these goals accomplished before the end of 2001.

As for interoperability, the exchange of information between computer systems is usually not the difficult piece. Agreeing on the data elements, values, and meanings is the difficult piece. You must have a common language in which to converse. Code sets, identifiers, values are important; less important is the structure or the transportation mechanism. A common language is achieved by either defining one language, or providing a mapping/translation correlation.

As for the other items noted above, they should be considered as factors to the selection process.

2. Draft Questionnaire: PMRI Message Format SDOs

Name of the Standards Development Organization (SDO). Specify the committee or subcommittee, if appropriate.

NCPDP Response:

National Council for Prescription Drug Programs (NCPDP)
WG11 (Work Group 11) Prescriber/Pharmacy Interface
Task Group Patient Profile

Name of the specific message standard. Include the number and version of the standard, if available.

NCPDP Response:

Working title of “Patient Profile” in a draft paper. The Task Group is planning completion of documents in 2001.

For General Information questions under Section 2 Draft Questionnaire, NCPDP does not have applicable standards currently in use for PMRI specifically. NCPDP, an ANSI SDO, is responsive to the industry’s needs using Standard Operating Procedures to ensure industry consensus and approval processes.

Whom to contact for more information. Please include the person’s name, E-mail address, phone and fax number, and position/title within the SDO.

Lynne Gilbertson
Director, Standards Development
lgilbertson@ncpdp.org
Phone: 602-957-9105 x 120
Fax: 602-955-0749

3. Proposed list of PMRI transactions to be considered for HIPAA standardization recommendations

May we please have your comments and critiques on the following list of PMRI transactions to be considered for HIPAA standardization in the first phase of PMRI standards selection.

  1. Admission/discharge/transfer information: from ADT or HIS to/from ancillary and EMR systems.
  2. Laboratory order and diagnostic study information: from any order entry system to laboratory and diagnostic systems.
  3. Laboratory and diagnostic study results: from laboratory and diagnostic systems to EMR's and/or HIS systems.
  4. Treatment/Medication Orders: from any order entry system to institutional pharmacies and various therapy departments.
  5. Radiological images: includes transactions from modalities to PACs, PACs to EMRs, and PACs to Workstations.
  6. Vital signs monitoring: from vital sign monitoring systems to bedside ICU systems.
  7. Prescription information: from provider to/from retail pharmacies.
  8. Documentation: from transcription systems or other sources to EMR or HIS.
  9. Intra-institutional charge information: from order systems and/or ancillary service systems to billing systems in institutions.
  10. Others:

NCPDP Response:

Regarding Item 7 – NCPDP has created a Prescriber/Pharmacist Interface standard called “SCRIPT” for transactions from provider to/from pharmacies for prescriptions. SCRIPT is an ANS standard. SCRIPT supports new prescriptions sent from the prescriber to a pharmacy, refill requests and responses from pharmacies to prescribers, compliance transactions to notify the prescriber of a dispensing event to monitor patients using their prescriptions, and others. Therefore, we do not feel that this transaction or business function should be included in PMRI, but rather recognized as a standard for its business functions.

NCPDP is not sure how #9 fits into PMRI, as this appears to be a billing event, covered under HIPAA transactions.

There may be a need for a simple request that gives the patient demographic information, pharmacy and medical allergies.

As for the other transactions, we feel it is important to look at the business functions – these may be separate business needs and therefore the standards should encompass those needs. And separate functions should be under different timeframes/schedules for expected implementation. PMRI should not be grouped into one timeframe unless analysis proves that all the business entities are tied together and need to converse.

4. Additional Comments or Critiques

  1. Should we consider other approaches or perspectives to selecting PMRI standards?
  2. Should we consider a broader or narrower scope for this first phase of selecting PMRI standards?
  3. Should we consider methods other than questionnaires to gather information on specific transaction standard candidates?
  4. Other comments or suggestions.

NCPDP Response:

NCPDP recommends a narrower approach. Healthcare industries cannot share all their PMR information soon. A project that is too large will have problems. A possibility would be to choose specific business functions and develop the sharing of information electronically, and then add other business functions after learning.

A questionnaire is a fine start to getting the word out and getting information back. However, each response comes from a different perspective and may mean totally different goals after the highest layer is peeled away.

A concern is how the information is managed/maintained – how is the sharing of updated information maintained among doctor/pharmacy/hospital/etc? Each of the standards must address how, when updated information is relayed to requestor, what does their system do with it? Do they believe it or wait until they have seen the patient? What if differing sources give differing information?

Also flaws or inconsistencies seen today in the paper or telephone world will not be fixed just by moving electronic. The foundation must be stable regardless of the medium.

I will recommend that this information be brought to the attention of the NCPDP members at the next Joint Technical Work Group meeting.

Thank you very much.