E-prescribing enables a prescriber to electronically send an accurate, error-free and understandable prescription directly to a pharmacy from the point-of-care and is an important element in improving the quality of patient care. The inclusion of electronic prescribing in the Medicare Modernization Act (MMA) of 2003 gave momentum to the movement, and the July 2006 Institute of Medicine report on the role of e-prescribing in reducing medication errors received widespread publicity, helping to build awareness of e-prescribing's role in enhancing patient safety. Adopting the standards to facilitate e-prescribing is one of the key action items in the Federal government’s plan to expedite the adoption of electronic medical records and build a national electronic health information infrastructure in the United States.
E-Prescribing and Related Standards in Proposed Rule CMS-4201-P
The proposed rule “Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications,” (87 FR 79452) published December 27, 2022, contained provisions related to e-prescribing standards at42 CFR 423.160, specifically:
- After a transition period, requiring the National Council for Prescription Drug Plans (NDPDP) SCRIPT standard version 2022011 proposed for adoption at45 CFR 170.205(b), and retiring the current NCPDP SCRIPT standard version 2017071, as the e-prescribing standard for transmitting prescriptions and prescription-related information (including medication history and electronic prior authorization (ePA) transactions) using electronic media for covered Part D drugs for Part D eligible individuals;
- Requiring the NCPDP Real-Time Prescription Benefit (RTPB) standard version 12 proposed for adoption at45 CFR 170.205(c)as the standard for prescriber real-time benefit tools (RTBTs) supported by Part D sponsors; and
- Revising current regulatory text referring to Health Insurance Portability and Accountability Act of 1996 (HIPAA) standards for eligibility transactions.
The public comment period for the proposed rule closed February 13, 2023.The final rule (CMS-4201-F), published April 12, 2023, did not address electronic prescribing-related proposals. CMS intends to address these proposals in subsequent rulemaking. Provisions adopted in a second final rule will be applicable to coverage no earlier than January 1, 2025.
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E-Prescribing and Its Significance: Electronic prescribing (e-prescribing) is a crucial aspect of modern healthcare, allowing prescribers to send accurate, error-free, and easily understandable prescriptions directly to pharmacies from the point-of-care. This process significantly improves the quality of patient care by reducing medication errors.
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Historical Context: The inclusion of electronic prescribing in the Medicare Modernization Act (MMA) of 2003 marked a pivotal moment, providing momentum to the adoption of digital prescriptions. The Institute of Medicine's report in July 2006 played a crucial role in raising awareness of e-prescribing's impact on enhancing patient safety, contributing to its widespread recognition.
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Federal Government's Initiative: The Federal government, as part of its plan to expedite the adoption of electronic medical records, has identified the adoption of standards to facilitate e-prescribing as a key action item. This aligns with the broader goal of building a national electronic health information infrastructure in the United States.
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Proposed Rule CMS-4201-P: The article references a proposed rule, "Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program...," published on December 27, 2022. The rule includes provisions related to e-prescribing standards at 42 CFR 423.160.
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Key Provisions in the Proposed Rule: The proposed rule outlines specific standards related to e-prescribing, including the transition to the National Council for Prescription Drug Plans (NDPDP) SCRIPT standard version 2022011. It proposes retiring the current NCPDP SCRIPT standard version 2017071. Additionally, the rule requires the adoption of the NCPDP Real-Time Prescription Benefit (RTPB) standard version 12 for prescriber real-time benefit tools (RTBTs) supported by Part D sponsors. There's also a revision of regulatory text related to Health Insurance Portability and Accountability Act of 1996 (HIPAA) standards for eligibility transactions.
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Public Comment Period and Final Rule: The public comment period for the proposed rule closed on February 13, 2023. The final rule, CMS-4201-F, published on April 12, 2023, did not address the electronic prescribing-related proposals. CMS (Centers for Medicare & Medicaid Services) intends to address these proposals in subsequent rulemaking, with provisions applicable no earlier than January 1, 2025.
This comprehensive analysis underscores the dynamic nature of e-prescribing regulations, reflecting the continuous efforts to enhance healthcare delivery through digital advancements. The information provided in the article highlights the evolving standards and their potential impact on the Medicare program, emphasizing the significance of staying informed about these changes in the healthcare landscape.
