Allows a Provider to Request a Patient’s Medication History from a State Prescription Drug Monitoring Program (PDMP)

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Comment

PDMP Medication History using NCPDP SRIPT v10.6

NCPDP SCRIPT v10.6 was piloted by the S&I Framework and shown to effectively allow a prescriber to inquire into a PDMP using NCPDP's SCRIPT RxHistory request transaction and receive a RxHistory response. It is recommended that this standard be named so that prescriber and pharmacy system vendors can enhance systems so that these entities can obtain PDMP patient information within workflow. SCRIPT version 2017071 has recently been named in a CMS NPRM for comment and includes recommended changes as a result of the 10.6 pilots.

The Pharmacy HIT Collaborative supports the use of NCPDP SCRIPT

The Pharmacy HIT Collaborative supports the use of NCPDP SCRIPT Standard, Implementation Guide Versions 10.6, as well as the move to NCPDP SCRIPT Standards, Implementation Guide, Version 2017071 and HL7 FHIR Implementation Guide, US Meds STU2 as soon as participants can be ready to implement such a change. We also recommend including NCPDP SCRIPT Standard Implementation Guide Version 2013101.

PDMP Standards

The Washington State Department of Health (DOH) appreciates the opportunity to submit these comments in response to the Office of the National Coordinator for Health Information Technology (ONC) request for public comments regarding the Interoperability Standards Advisory (ISA). DOH operates the Prescription Drug Monitoring Program (PDMP) in the state of Washington. DOH supports the proposed switch to the National Council for Prescription Drug Programs (NCPDP) 2017-071; however, DOH respectfully requests that the proposed deadline to implement NCPDP 2017-071 be extended to ensure that small to medium sized providers and critical access hospitals have a reasonable period of time to implement.

DOH supports NCPDP 2017-071 and recognizes the benefits, including allowing the system to query the PDMP more than once every 24 hours (which is the current maximum), and allowing the system to send dispense level patient information. A previously adopted Centers for Medicare and Medicaid Services (CMS) rule, CMS-4182-F (Changes to the Medicare Advantage Prescription Drug Benefit Program, aka Medicare part D), required adoption of NCPDP 2017-071 for e-prescribing by January 1, 2020. By moving toward adoption of NCPDP 2017-071, the health care system will keep PDMP in harmony with other federal regulations.

DOH supports the switch to NCPDP 2017-071, but we want to ensure that the deadline to do so is feasible. Currently, Washington State cannot accept NCPDP 2017-071 queries, as DOH’s system uses NCPDP 10.6 for the PDMP. NCPDP 2017-071 is not backward compatible with NCPDP 10.6. DOH staff contacted our electronic medical record vendors and the vendors indicated their certified Health IT software that meet these new requirements will be released in summer of 2019. Hospitals’ adoption of this new version will occur in a rolling adoption period after the release date. For DOH’s PDMP system, we hope to be able to begin the switch to NCPDP 2017-071 by January 1, 2020. DOH anticipate needing to support both NCPDP 2017-071 as well as 10.6, for a transition period from January 1, 2020 through approximately January 1, 2021, assuming not all providers convert simultaneously.

In addition, DOH believes it would also be helpful for CMS to clarify whether, if the community pharmacy could not accept the prescription due to the different versions, this would be considered an exclusion for the hospital to maintain both versions. DOH recommends that CMS consider providing administrative support for public health, community pharmacies, small- to medium-sized providers, and critical access hospitals to upgrade to NCPDP 2017-071. If communities do not have the resources or incentives to upgrade, it will be crucial for PDMP systems to support both versions during this transition period.

The proposed deadline to implement NCPDP version 2017-071 should be extended to ensure that PDMP systems and the health care system have a reasonable period of time to implement. DOH recommends that the ISA allow for NCPDP v10.6 grandfathering until January 1, 2021.

Sincerely,

John Wiesman, DrPH, MPH

Secretary of Health

Washington State Department of Health

 

NCPDP Comment

  1. For NCPDP SCRIPT Standard, Implementation Guide, Version 10.6, modify testing tool availability to Yes. Test Tool Link: https://tools.ncpdp.org/erx/#/home
  2. For NCPDP SCRIPT Standard, Implementation Guide, Version 2017071, modify testing tool availability to Yes. Test Tool Link: https://tools.ncpdp.org/erx/#/home
  3. NCPDP SCRIPT Standard is a mature standard that can alleviate identified interoperability issues.