Are LTPAC Vendors and Providers Ready for the New ePrescribing Standards?

| September 09, 2014

Standards for ePrescribing changed dramatically on Nov. 1, 2014, for some providers of long-term and post-acute care (LTPAC) that participate in Medicare Part D. More than half (53.9%) of vendors responding to a recent CAST survey said they were ready for the change. However, almost three-quarters (72.2%) of providers said they were not.

Standards for ePrescribing changed dramatically on Nov. 1, 2014, for some providers of long-term and post-acute care (LTPAC) that participate in Medicare Part D. 

More than half (53.9%) of vendors responding to a recent CAST survey said they are ready for the change. However, almost three-quarters (72.2%) of providers said they were not.

As of Nov. 1, 2014, LTPAC providers that send prescriptions or medication orders electronically to a pharmacy must use the National Council for Prescription Drug Programs (NCPDP) SCRIPT standard, namely “NCPDP SCRIPT 10.6” or higher standard if:

  • The receiving pharmacy is a separate legal entity from the LTPAC organization.
  • The prescriptions are eligible for reimbursement under Medicare Part D.

If your organization participates in ePrescribing and meets the criteria listed above, you must send electronic prescriptions using NCPDP SCRIPT version 10.6 or higher. Otherwise, claims associated with the electronic prescriptions may not be paid, if Medicare Part D is the payer.

“The NCPDP requirement affects prescriptions and medication orders to an outside pharmacy (a separate legal entity) using other standards such as HL7 or computer-generated fax (eFax),” says CAST Executive Director Majd Alwan. “Prescriptions and medication orders being sent using anything other than NCPDP SCRIPT 10.6 will no longer be compliant electronic communications regulations after Nov. 1.”

Options for Providers Sending ePrescriptions

If your organization has implemented an interface using HL7 or electronic computer-generated fax (eFax) for the transmission of electronic prescription information to pharmacies that are separate legal entities, you had until Nov. 1, 2014 to either:

  • Adopt a platform that utilizes NCPDP SCRIPT 10.6 standard or higher, or 
  • Convert back to manual processing of prescription orders. Approved manual processing methods include delivering a prescription from a physician order pad by hand, phone or mail; or manually faxing a physician order or a printed copy of an order from a physician. Electronic computer-generated faxes (eFax) and HL7 transmissions will not be compliant with regulations and will not be accepted.

SCRIPT Exceptions and Limitations

According to the final rule, electronic transmission of prescriptions or prescription-related information by means of computer-generated facsimile (eFax) is only permitted in instances of temporary/transient transmission failure and communication problems that would preclude the use of the NCPDP SCRIPT Standard. These instances include a natural disaster, or if a server is down. 

The Sig Segment of the SCRIPT standard, which is used for writing medication taking/administration instructions, is limited to a 140 characters. 

However, Sig has not been adopted Under Part D, so it falls outside the scope of the Part D ePrescribing program. 

Consequently, the computer-generated fax requirement does not apply to Sig itself. In instances where Sig exceeds 140 characters, the LTPAC provider could use an alternate method of communicating the order to the pharmacy, such as eFax, as long as the prescription itself is sent using NCPDP SCRIPT 10.6, according to a clarification from CMS.

LeadingAge CAST Action

To help members prepare for the Nov. 1 deadline, CAST promoted a webinar organized by CAST Supporter HealthMEDX on Sept. 18. The webinar addressed the latest developments in the pending ePrescribing change.

CAST also created 2 online surveys to gauge the readiness of LTPAC & Pharmacy EHR vendors and LTPAC providers. Here are the results: 

  • Concerns: Two-thirds (64.7%) of the 19 providers and almost all (88.1%) of the 13 LTPAC EHR vendors responding to the surveys said they had concerns about the Nov. 1 deadline. 
  • Implementation rates: More than half (53.9%) of vendors and only 10.5% of providers said they had implemented NCPDP SCRIPT 10.6 standard or higher to send and receive standard prescription/medication order messages. Almost three-quarters (72.2%) of providers said they had not implemented the NCPDP SCRIPT 10.6 standard at all.
  • Pharmacy readiness: Vendors report that less than half (45%) of the pharmacies they know are able and willing to send and receive prescription/medication order messages bi-directionally using NCPDP SCRIPT 10.6 standard or higher. Two-thirds (69.2%) of vendors who had or are developing the standard said it has been tested by a pharmacy. Frameworks, Omnicare, PharMerica, and QS1 were the most common test partners. Only 11.1% of providers had tested their system with a pharmacy. 
  • Customer readiness: Only a few providers -- between 5.6% and 9% -- are currently live and using NCPDP SCRIPT 10.6 standard or higher to send and receive prescription/medication order messages bi-directionally, according to both surveys. 

A number of providers are not currently using NCPDP SCRIPT at all. Instead:

  • Between 55% and 57% of providers are currently using manual fax/mail/telephone, according to both surveys.
  • Vendors reported that 33.3% of their clients are currently using the HL7 Interface, while 54% of providers said they are using the HL7 interface.
  • Vendors reported that 38.9% of their clients are currently using computer-generated fax, while 10% of providers reported using these faxes.

NCPDP 10.6: Advocacy Action

Six LTPAC Health IT organizations, including LeadingAge and CAST, recently sent a letter asking CMS to consider steps to help ease the transition to NCPDP 10.6 while protecting patient safety. 

The letter, spearheaded by the National Association for the Support of Long Term Care (NASL), asked CMS to take the following steps:

  • Allow e-faxing to continue, rather than requiring providers to revert to manual processes during their transition to adopting the NCPDP SCRIPT 10.6. The continuation of e-faxing would limit the potential for error during the transition to NCPDP SCRIPT 10.6.
  • Direct the Prescription Drug Plans to provide LTPAC pharmacies with a grace period for recoupment and audit as it relates to use of the NCPDP SCRIPT 10.6 standard. This would allow testing and implementation in LTPAC settings to continue uninterrupted over the next 6 to 12 months.
  • Inform the CMS Survey & Certification Group of this transition period and give consideration for settings that are in the midst of this transition.

In its response, CMS reported that the continuation of e-faxing would require a change to the rule, which could take months. 

Issues regarding the transition to NCPDP SCRIPT 10.6 may be resolved before the rule change could take effect, said the response. CMS did agree to monitor issues around implementation of this policy and is eager to hear from us should problems with recoupment of valid prescriptions or other such issues arise.  

Advice for Providers

Are you a provider that currently uses electronic health records (EHR), ePrescribing or Computerized Physician Order Entry (CPOE) platforms to electronically send prescriptions or medication orders to outside pharmacies? 

If so, CAST strongly recommends the following steps: 

  • Ask the vendors of your EHR, ePrescribing or CPOE platform to identify how the information is sent and what standard (including the version) is being used.
  • If any standard other than NCPDP SCRIPT, version 10.6 or higher, is being used, work with the vendors to develop a plan that ensures compliance. This could involve either upgrading to NCPDP SCRIPT version 10.6 or higher, or reverting to manual processes. 
  • If you plan to upgrade to NCPDP SCRIPT 10.6 or higher, make sure your vendor has tested the platform with the pharmacy or pharmacies with which you work. It is prudent to develop a “Plan B” that involves using manual processes in case you encounter any difficulties with the upgrade, testing or go-live.
  • Make sure your plan also complies with pertinent state regulations, including any rules by your State Board of Pharmacies, particularly those related to a prescriber’s signature and prescription of controlled substances, if applicable.
  • Work internally to update your operating procedures, train staff on new approved processes and protocols, and ensure that all staff follow the updated procedures to maintain compliance. 
  • Inform CAST if you encounter issues during the implementation that warrant intervention and or advocacy. 

For more information, refer to NCPDP’s recent educational webinar on the topic and the answers to the questions asked during the webinar.