Comment

NCPDP Comment

NCPDP recommends removing NCPDP SCRIPT Standard, Implementation Guide, Version 2022011, as this version was never implemented. NCPDP SCRIPT Standard Implementation Guide, Version 2023011 is the next version named by ASTP/ONC and Medicare. Federally required should be changed to a Yes for the NCPDP SCRIPT Standard Implementation Guide, Version 2023011.

Pharmacy HIT Collaborative (PHIT) comment

PHIT supports NCPDP’s recommendation to update Structured and Codified Sig Format Implementation Guide Version 2.1 to Structured and Codified Sig Format Implementation Guide Version 2.2.

NCPDP Comments

NCPDP SCRIPT Standards, Implementation Guide, Version 2017071 update adoption level to 3.

Requirement for weight and height for prescriptions

Except for chemotherapeutic agents and a very few other medications, a patient's height is not necessary to determine medication dosing.  Medications such as eye drops, ear drops, skin creams, and inhaled medications (bronchodilators, inhaled steroids, etc.) do not require weights at all.  These categories should be exempted from requiring height and weight data on prescriptions as refills and even initial prescriptions are often sent in or called in without the child being actually seen in the office.  ("Pink Eye" does not always need an office visit!)  Imagine how disruptive it would be if you had to leave work, pick up a child from school or daycare, and come to the pediatrician's office just to get an update weight and height for your eye drops or albuterol refill!  Moreover, as telemedicine becomes more prevalent, patients may be evaluated by a physician and prescriptions sent in without there being an actual physical visit to an office where updated heights and weights are obtained.  This is especially true for behavioral health conditions such as ADHD and anxiety/depression.  Again, medications would be refilled without a patient actually being present for a new height and weight. (These medications are not particularly dosed by weight anyway.)

As a practical matter, most pediatricians will not send in prescriptions for patients they have not seen in over a year, but for those patients who are current, as long as we can use the most recent measurements we have on-file, this policy should be workable--especially if you eliminate the height requirement and exempt the categories noted above.

 

Alan L. Schwartz, M.D.; Pediatrician,

Indianapolis, IN

NCPDP Comment

  1. Add the following:
    1. Observation Element in NewRx Transaction

Type-Implementation Specification

Standard Implementation/Specification- NCPDP SCRIPT Standard, Implementation Guide, Version 2017071

Standards Process Maturity – Final

Implementation Maturity- Pilot

Adoption Level – 1

Federally Required – No

Cost – $

Test Tool Availability – Yes

Pharmacy HIT Collaborative's Comments on ONC's Proposed 2018 ISA

The Pharmacy HIT Collaborative supports the use of Structured Codified Sig Format Implementation Guide Version 2.1.  The Collaborative also supports the move to NCPDP SCRIPT Version 2017071 as soon as participants can reasonably be ready to implement such a change.