Requirements for E-Prescribing Standards

Introduction

As a knowledge base provider, Medi-Span, part of Wolters Kluwer Health, is limiting our responses, below and in the spreadsheet, to the standards and code sets that address drug information data and a patient’s medical history data.

NCPDP Script Standard

Medi-Span supports NCPDP’s SCRIPT Standard as the standard for the transmission of electronic prescriptions.  SCRIPT’s widespread implementation lends itself to being the foundation for the enhanced e-prescribing standard described in the Medicare Prescription Drug, Improvement & Modernization Act of 2003 (the “Act”).  The SCRIPT Standard is a solid foundation to build upon as it contains the data necessary for basic communications between organizations involved in e-prescribing. 

Recommendations for the enhancements to the SCRIPT Standard

As noted in previous testimony by NCPDP in March 2004, enhancements to the current SCRIPT Standard are needed.  Below is a summary of Medi-Span’s recommended enhancements:

1. Incorporation of nationally recognized and adopted terminologies within the standard.
   
   Currently, the SCRIPT Standard allows drug products to be identified by text strings and by proprietary drug terminologies such as Medi-Span’s proprietary drug code set.  From previous testimony, Medi-Span recognizes the desire for cost-neutral or “pre-paid” terminology solutions.  Medi-Span supports the use of RxNorm as a means to facilitate interoperability between e-prescribing systems that use different proprietary drug code sets. 

   Medi-Span recommends that the SCRIPT Standard continue to include the prescription as text strings and as the proprietary drug terminology code set used to generate the electronic prescription or the dispense the prescription.  In addition, nationally recognized code sets, such as RxNorm, should also be included in the SCRIPT Standard to facilitate interoperability as mentioned earlier. 

   Medi-Span believes that the continued inclusion of text strings and proprietary code sets will facilitate quicker adoption of e-prescribing systems.  This approach eliminates the need for prescriptions to be transmitted solely by nationally adopted code sets, as these code sets are evolving.  In addition, this approach also provides the opportunity for a human to read the transmitted text string against the translated code set, thereby providing the health care professional the opportunity to check for translation errors between code sets.

   Medi-Span believes that limiting the transmission of electronic prescriptions to the nationally adopted code sets will slow the adoption of e-prescribing as these code sets and supporting systems evolve.

2. Incorporation of DUR alert summary and communication between parties as noted in the Act.
   
   The Act describes the exchange of information on drug-drug interactions, warnings or cautions, and when indicated, dosage adjustments.  We recommend that this information be supplied as a summary of the DUR screening alerts generated in the prescribing, dispensing, or reporting process along with the action taken.  For example, if a prescriber is alerted of an interaction between the new prescription and a drug already on the patient’s profile but decides it is appropriate to dispense the new drug, this action should be transmitted to the dispensing site so that the dispenser is aware of the prescriber’s decision.  As a part of NCPDP’s Telecommunications Standard, it is routine to transmit DUR results between pharmacies and insurers.  This allows DUR results to be shared even though the systems on either end may be using different drug interaction screening systems from different knowledge base vendors.  Medi-Span’s recommendation is to incorporate this same approach into the SCRIPT Standard by allowing for the transmission of action(s) resulting from a DUR alert.
   
   Medi-Span does not recommend transmitting complete monographs of DUR information.  This information should reside within the e-prescribing system, but is not necessary for the electronic transmission of a prescription.
3. Recommend the incorporation of a longer drug description or make the use of the dosage form and dose strength fields available in SCRIPT mandatory in the version of the standard to be implemented.
   
   Currently, the Drug Name field of SCRIPT is mandatory while the dosage form, dose strength, and dose strength unit of measure are treated as conditional fields.  Thus, implementations of SCRIPT incorporate the dosage form, dose strength, and dose strength unit of measure in the 35-character Drug Name (Item Description) field of SCRIPT.  Thirty-five characters for the drug description is no longer sufficient.  Recent Joint Commission for Accreditation of Healthcare Organizations (JCAHO) patient safety guidelines and Institute of Safe Medication Practices (ISMP) recommendations are to remove dangerous medical abbreviations from drug orders.  These guidelines cannot be adopted with the constraint of a 35-character field length.  Medi-Span recommends either the addition of a drug description extension for drug descriptions longer than 35-characters or changing the dosage form, dose strength, and dose strength unit of measure to be mandatory fields in the SCRIPT Standard.
   
   
4. Incorporation of the transmission of formulary information for a specific patient’s prescription as noted in the Act.
   
   NCPDP’s portfolio of standards includes a standard for transmitting an entire formulary.  This standard can be adapted for inclusion in SCRIPT to incorporate the data necessary pieces for formulary transmission between e-prescribing organizations.