ePrescribing in LTC – What You Don’t Know Can Hurt (Your Patients)

As part of the Medicare Modernization Act of 2003, the Centers for Medicare and Medicaid Services (CMS) created a rule to encourage ePrescribing by physicians and provided them with incentives to purchase ePrescribing software and later to adopt meaningful of electronic data.  However, no such incentives were provided for LTC/Post-Acute (:LTCPAC) facilities.

Because of the challenges and lack of financial support to adopt the proposed changes, CMS provided an exemption to this rule for ePrescribing in LTC.   Also, at that time the ePrescribing standard in effect, NCPDP SCRIPT 8.1, could not accommodate necessary workflow requirements for LTCPAC facilities.

However, with the recent adoption of NCPDP SCRIPT 10.6 as the only standard for transmission of electronic prescriptions, CMS has decided to lift this LTCPAC exemption effective November 1, 2014.

So what does this mean for your facility or pharmacy?

Well, let’s start with how CMS defines ePrescribing.  You may think that ePrescribing is only the electronic transmission from a prescriber to a dispenser.  However, CMS defines ePrescribing as “the transmission using electronic media, of prescription or prescription-related information between a prescriber, dispenser, pharmacy benefit manager or health plan, either directly or through an intermediary, including an ePrescribing network.” The definition further states that ePrescribing “includes, but is not limited to, two-way transmissions between the point of care and the dispenser.” [42 CFR §423.159]

The “e-” in “ePrescribing” simply refers to “electronic” – as in prescriptions that are transmitted “electronically.” That includes computer-generated faxes (aka “e-faxes”).

Therefore, after November 1, 2014 if your facility utilizes a system that stores medication order information “electronically” such as an electronic health record (EHR) and then sends a computer-generated fax to the pharmacy, that transmission must meet the NCPDP SCRIPT 10.6 standard.

Please note that this rule only applies to medication orders for Medicare Part D residents.  However, these residents comprise the majority of patients in LTCPAC facilities including most dual-eligibles.

However, this rule does not apply

1. If you currently do not store medication orders in an EHR and only transmit orders to the pharmacy via telephone or manual faxes
2. If your facility and the pharmacy are part of the same legal entity

So if you are currently sending medication orders to the pharmacy electronically including e-faxes or direct electronic transmission what should your facility do now?

• Contact your EHR vendor and pharmacy to see if their systems are compatible with the NCPDP SCRIPT 10.6 standard for any electronic medication order transmissions including computer-generated faxes.
• If not, will need to upgrade your systems to meet the standard or revert to manual faxing or calling orders to the pharmacy after November 1, 2014.

Rest assured that alixaRx is working with Point Click Care and other vendors and will be fully compliant with the NCPDP SCRIPT 10.6 standard by November 1^st.

Source: Morton, Cynthia   Stakeholders need to prepare for the loss of long-term care’s exemption to ePrescribing www.NASL:.org