Sunday, July 13, 2008

H.R.6331 Medicare Improvements for Patients and Providers Act of 2008

Here is an excerpt from the recently passed legislation: carrots, sticks and all.
I am surprised at small size of the initial bonus and the quickness with which it will be decreased.

Let's get some opinions. SV

The bonuses would seem to decrease over the years:

`(C) APPLICABLE ELECTRONIC PRESCRIBING PERCENT- For purposes of subparagraph (A), the term `applicable electronic prescribing percent' means--

`(i) for 2009 and 2010, 2.0 percent;

`(ii) for 2011 and 2012, 1.0 percent; and

`(iii) for 2013, 0.5 percent.';

While the penalalties would increase over the years (percent of fee schedule after penalty is applied):

ii) APPLICABLE PERCENT- For purposes of clause (i), the term `applicable percent' means--

`(I) for 2012, 99 percent;

`(II) for 2013, 98.5 percent; and

`(III) for 2014 and each subsequent year, 98 percent.

The Government will revisit the incentives/disincentives base upon several variables including:

(c) GAO Report on Electronic Prescribing- Not later than September 1, 2012, the Comptroller General of the United States shall submit to Congress a report on the implementation of the incentives for electronic prescribing established under the provisions of, and amendments made by, this section. Such report shall include information regarding the following:

(1) The percentage of eligible professionals (as defined in section 1848(k)(3) of the Social Security Act (42 U.S.C. 1395w-4(k)(3)) that are using electronic prescribing systems, including a determination of whether less than 50 percent of eligible professionals are using electronic prescribing systems.

(2) If less than 50 percent of eligible professionals are using electronic prescribing systems, recommendations for increasing the use of electronic prescribing systems by eligible professionals, such as changes to the incentive payment adjustments established under section 1848(a)(5) of such Act, as added by subsection (b).

(3) The estimated savings to the Medicare program under title XVIII of such Act resulting from the use of electronic prescribing systems.

(4) Reductions in avoidable medical errors resulting from the use of electronic prescribing systems.

H.R. 6331

Saturday, July 12, 2008

DEA e-prescription regulations released June 27 2008

The highlights:

1) Prescriber in-person identity proofing (fortunately this can be done at a DEA-registered hospital)

2)Authentication protocol would have to be two-factor

3)Pharmacies would have to regularly check on the prescriber's status

4)Both the electronic prescription service provider and the pharmacy system provider would need to obtain annual third-party audits for security and processing integrity. 3rd party audits

Here is an abridged version of the 62 page document.

Public comment is strongly recommended. SV

DEA considered and is proposing two options:

Electronically signed prescriptions with security controls. Under this alternative, practitioners would be required to undergo in-person identity proofing and submit documentation of that to a service provider. The identity proofing would be conducted by a DEA-registered hospital, a State licensing board, or State or local law enforcement agency. The service provider would be required to check the validity of the DEA registration and State license before issuing an authentication protocol to be used to sign controlled substance prescriptions. The authentication protocol would have to be two-factor, with one factor stored on a hard token (e.g., a PDA, a multifactor one-time-use password token, a thumb drive, a smart card). DEA would also impose certain system requirements related to the prescription elements and their presentation; most existing systems may already meet these requirements. The prescription would have to be transmitted immediately upon being signed and the service provider would have to digitally sign and archive the record before transmitting the plain text prescription to the intermediaries. The pharmacy would have to digitally sign and archive the prescription as received. The pharmacy system would need an internal audit trail to record any attempts to alter a record and conduct internal checks for such attempts. Both the electronic prescription service provider and the pharmacy system provider would need to obtain annual third-party audits for security and processing integrity. The service provider would have to generate a monthly log, which practitioners would be required to check for obvious anomalies. The rationale for each of the requirements is presented under the discussion of the proposed rule below.
Modified digitally signed prescriptions. Due to the current use of
digital signatures by Federal health care systems, and the added security afforded by such signatures, DEA is proposing to allow practitioners that prescribe controlled substances at Federal health care facilities (e.g., Department of Veterans Affairs, Department of Defense) the additional option of using digital certificates, issued by such Federal agencies, to sign controlled substance prescriptions issued in the course of their official duties within those facilities. These Federal agencies would need to determine that the practitioner is authorized and registered, or exempted from the requirement of registration, to prescribe controlled substances. The private key would be required to be stored on a hard token. Federal agencies will already be meeting this requirement in issuing Personal Identification Verification (PIV) cards under Federal Information Processing Standard 201. Most of the system requirements would be the same as in the previous option except that the Federal agency could elect to allow the practitioner to digitally sign and archive the prescription once the DEA-required elements are complete and transmit later when other information has been added (e.g., retail pharmacy URL). The Federal agency would not have to digitally sign the record as transmitted. The pharmacy requirements would be the same. The digital signature would not be transmitted to the pharmacy; the pharmacy would not have to validate the record. However, if a Federal agency wished to include the digital signature as part of the transmission, DEA is permitting this alternative. In that case, the pharmacy would be required to validate the digital signature, but would not be required to digitally sign the prescription as received. Because a Certification Authority would issue the digital certificate and because record integrity is more assured with a digital signature, DEA would not require a check of a monthly log or third-party audits for security. The rationale for each of the requirements is presented under the discussion of the proposed rule below.

National Register

Thursday, July 10, 2008

Horizon BCBSNJ Sponsors Hospitals adoption of E-Medication Technology

This is a wonderful application of existing technology that will yield immediate benefits. Concurrent with this press release was news of the SureScripts-RxHub merger. As we await the "construction" of RHIOs, the Horizon sponsorship and hopefully others like it will permit patients to reap the benefits of what is readily available. SV

Horizon BCBSNJ First Insurer in the Nation to Provide Financial Support to Select Network Hospitals for the Adoption of E- Medication History Technology

The program will be administered through RcopiaAC MedHx by DrFirst which connects to the largest and most comprehensive medication history data sources available in the market. RcopiaAC collects, displays, and documents patient medication history information at the time of admission and connects directly to hospitals taking part in the program. When a patient is admitted into the hospital, RcopiaAC will send an electronic medical history request to multiple sources including RxHub, Surescripts, DrFirst’s nationwide network of Rcopia e-prescribing users, and DrFirst’s EMR Open Borders partners. When medication history information is found, it will be submitted back to the hospital. The system will be completely automated and the information will be relayed in real time.

Horizon BCBSNJ

Tuesday, July 01, 2008

Federal budget:your opportunity to act

Here is the link for the ACPONLINE CAPWIZ site. SV


Here is the link for a sample letter for patients.

SureScripts and RxHub Merger= SureScriptsRxHub

It's not quite the connection of the Atlantic and Pacific railroads, but pretty close.
SureScripts was a formed by the National Association of Chain Drug Stores (NACDS) and the National Community Pharmacists Association (NCPA). RxHub was founded by the nation’s three largest PBMs – CVS Caremark Corporation, Express Scripts, Inc. and Medco Health Solutions, Inc. Local pharmacies will now share the same network as the mail-order houses. One certification should get the free-standing e-Prescribing and Electronic Health Record vendors access to almost everyone. Less cost for the vendors may mean less cost to deploy. SV

In 2008, the combined organization expects to transmit 100 million electronic prescription transactions and respond to more than 70 million requests by physicians confirming information about their patients’ drug coverages and medication histories. With appropriate patient consent, the combined organization will extend this information to clinicians caring for more than 200 million patients across the United States.

Easy, Efficient, Accurate, Safe and Secure
With this information more readily available, the process of prescribing medications is measurably improved by:

providing physicians with added knowledge of their patients;
enabling a more informed choice of therapy;
ensuring that the medicine intended by the physician is actually and accurately communicated to the pharmacy;
allowing patients to weigh important economic considerations within a range of appropriate clinical options before a prescription is written; and
adding convenience to the overall process.