Good afternoon Mister Chairman and members of the Subcommittee, my name is Cliff Berman and I am appearing today on behalf of Allscripts Healthcare Solutions, Inc. I am Senior Vice President and General Counsel of Allscripts.
Allscripts recommends that electronically transmitted prescriptions and related computer-to-computer communications between physicians and pharmacies be included within the electronic health care transactions covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Allscripts further recommends that the SCRIPT Standard format created and maintained by the National Council for Prescription Drug Programs (NCPDP) be adopted as the message format for these computer-to-computer communications.
Allscripts is the leading provider of wireless point-of-care solutions for physicians. Over 5,000 physicians use our wireless applications to perform a variety of tasks, including e-prescribing, lab orders, dictation and charge capture. Our e-prescribing application has been used to write millions of prescriptions. Our latest software, called Rx +TM, performs drug utilization review (DUR) against other drugs prescribed for the patient to identify any drug interactions, therapeutic duplication or drug-disease contra-indications. It also alerts the physician to possible problems with drug allergy and drug dosing. The Rx+ software also indicates whether the chosen drug is included on any formulary that may be administered by the patient’s prescription benefit plan and, if not, identifies formulary alternatives for the physician’s consideration. Finally, and perhaps most importantly, the Rx+ software creates an electronic prescription that is legible.
Once the prescription is created, the Rx+ software allows three options: the physician can print a hard copy of the prescription for the patient to take to the pharmacy, the physician electronically fax the prescription from the physician’s computer to the pharmacy’s fax machine, or the physician can electronically transmit the prescription from the physician’s computer directly into the pharmacy’s computer via SCRIPT Standard. While all three formats are superior to handwritten prescriptions, the computer-to-computer format holds the most promise in the fight to decrease medication errors, since it eliminates the need for pharmacy staff to retype the prescription into the pharmacy’s computer. The computer-to-fax and electronic paper prescriptions formats still dominate, however, because of the slow adoption of SCRIPT Standard technology by the pharmacy community. Some of the mail service pharmacies and the largest pharmacy chains have implemented or begun implementation of SCRIPT Standard, but most pharmacies have not.
We are hopeful that adoption of e-prescribing technology will be accelerated by the inclusion of electronically transmitted prescriptions and related computer-to-computer communications between physicians and pharmacists as transactions covered by HIPAA and the adoption of SCRIPT Standard as the standard message format for those transactions.
Allscripts is a member of the National Council for Prescription Drug Programs and we are active on its Work Groups. Allscripts implemented NCPDP’s SCRIPT Standard in late 1998 at an approximate cost of $25,000. The time to implement was approximately two months. SCRIPT Standard transmissions are routed to the pharmacy through a switch. Some pharmacies maintain their own switch and others contract for that service. It takes about 6 weeks of testing time for each connection we make to a new switch.
There are really no alternatives to SCRIPT Standard in this arena. While HL7 has a message standard that supports inpatient drug orders, only SCRIPT Standard applies to the unique requirements of outpatient prescription transactions. The transmissions that SCRIPT standard supports include new prescriptions from the prescriber to the pharmacy, requests for refills or prescription changes from the pharmacy to the prescriber, and responses to those requests from the prescriber back to the pharmacy. Although issues exist around reaching agreement on common code sets, identifiers and data elements, we are satisfied with the SCRIPT Standard message format itself.
We utilize SCRIPT Standard version 1.5, which is the version in use by the few pharmacies that have implemented electronic prescribing software. We will implement version 4.0 when there are pharmacies that have implemented it. Given the relative frequency with which new versions of these standards are released, we would recommend some flexibility in adopting a specific version so that the Rules do not mandate obsolete versions. New releases tend not to be major overhauls, but rather add data elements based on suggestions by users. Perhaps the standard chosen should be the version then in current use and all subsequent releases.
Allscripts would be happy to work with the Subcommittee to address these details as it formulates its recommendation to the Department of Health and Human Services. Thank you for your consideration of our comments. I would be happy to answer any questions the Subcommittee might have.