Preparing for the Medicare Part D Requirements for e-Prescribing in Long-Term Care

Andrew Morgan, MBA Insurance Specialist, CMS Gary Schoettmer, R.Ph. CIO, Advanced Pharmacy Co-Chair, NCPDP LTPAC Work Group June 5, 2014

Sponsored by:

Speaker Disclosure

• Andrew Morgan and Gary Schoettmer report

no actual or potential conflicts of interest

associated with this presentation

Accreditation Statement

The Institute for Wellness and Education is accredited by the Accreditation Council for Pharmacy Education as a provider of continuing pharmacy education. Attendees who participate in the interactive portion and submit the completed evaluation form at the conclusion of the program will have credit for 1.0 hour(s) of continuing pharmacy education (0.10 CEU(s)) uploaded to CPE Monitor within 60 days after the program date. ACPE program numbers are: 0459-0000-14-052-L04-P & 0459-0000-14-052-L04-T

Accreditation Statement

This program has been pre-approved by the American Nursing Credentialing Center (ANCC) to provide continuing education credit to nurses. Attendees who participate in the interactive portion and submit the completed evaluation form at the conclusion of the program will receive a certificate for 1.0 contact hour within 4 to 6 weeks after the program date.

Program Objectives

• Recognize the requirements of the Medicare Part D ePrescribing Program

• Identify what the MMA Transaction Standards are for the Medicare Part D ePrescribing Program

• Define ePrescribing under MMA

• Assess the value ePrescribing brings to your organization

• Restate the new Medicare Part D requirements for ePrescribing in Long-Term Care

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Agenda

• e-Prescribing Overview

• Regulatory Requirements

• e-Prescribing in Long-Term Care

• Next Steps

• Questions

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e-Prescribing Overview

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e-Prescribing – CMS Definition

E-prescribing means 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 e-prescribing network. E-prescribing includes, but is not limited to, two-way transmissions between the point of care and the dispenser. (42 CFR §423.159)

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e-Prescribing

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e-Prescribing using SCRIPT v10.6

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e-Prescribing using SCRIPT v10.6

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e-Prescribing - Benefits

• Compliant with regulatory requirements

• Supports efforts to improve the standard of care

• Increases administrative efficiency

• Welcomed by patients

• Safe and secure

• Allowed in all 50 states

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e-Prescribing – Who is Involved? • Prescribers - individual practitioners, clinics, hospitals, provider

associations

• Pharmacies

• Software Vendors – pharmacy, EMR

• Trade and Professional Associations

• Labs and Ancillary Services

• State and Federal Governments

• Standards Development Organizations

• Terminology and Code Set Organizations

• Health Plans, Payers, and Processors

• Intermediaries

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e-Prescribing – Success • Nearly everyone is e-Prescribing except LTC

• How long have they been doing it?

• 93% of Community Pharmacies can accept e-Prescribing transactions*

• 25% Increase in Physicians routing Prescription in 2012*

• 38% Increase in Prescription Routing (788M) in 2012*

• Electronic Health Record (EHR) vs. Stand-alone e-Prescribing system*

• 13% Stand-alone systems

• 87% EHR * Surescripts 2012 National Progress Report on e-Prescribing

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Electronic Prescribing Use*

• e-Prescription Routing increased 38% in 2012

• 44% of prescriptions dispensed were routed electronically Prescription Benefit Responses increased 33% in 2012

• 48% of visits generated an electronically delivered medication history

* Surescripts 2012 National Progress Report on e-Prescribing

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Regulatory Requirements

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Timeline Date Activity

November 2005 Medicare Program; E-Prescribing and the Prescription Drug Program; Final Rule

2006 E-Prescribing Pilots

June 2006 IFC to adopt NCPDP SCRIPT Standard version 8.1 on a voluntary basis

April 2008 Second Final Rule adopted Initial Standards

November 2008 CY 2009 Physicians Fee Schedule- lifted the exemption to the Computer Generated Fax (CGF) effective (1/1/12)

January 2009 CMS published HIPAA Modification Final Rule – Updates to two Foundation Standards

July 2010 IFC to adopt NCPDP SCRIPT Standard version 10.6 on a voluntary basis.

November 2012 CY 2013 Physicians Fee Schedule final rule adopted the SCRIPT Version 10.6 standard effective (10/1/13) and Lifted the Long Term Care Exemption effective(11/1/14)

December 2013 CY 2014 Physicians Fee Schedule- adopted a newer version of the Formulary and Benefits Standard (3.0) effective (2/28/15)

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e-Prescribing – Original Exemptions

• Computer-generated facsimile (CGF) – expired January 1, 2012

• e-Prescribing of Controlled Substances (EPCS) – DEA Interim Final Rule w/ Comment (IFC)

• Allows for EPCS

• Long-Term Care – expiring November 1, 2014

• Same legal entity exemption

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SCRIPT v10.6 Exchange between prescribers, pharmacies, intermediaries, payers

• New prescription request *

• Change of prescription *

• Prescription cancelation *

• Refill/renewals request/response * or Resupply in LTC

• Fill Status notification *

• Medication history exchange *

* Named in regulation

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Controlled Substances

Final Rule: http://www.gpo.gov/fdsys/pkg/FR-2010-03-31/pdf/2010-6687.pdf

The SCRIPT Implementation Recommendations Document contains guidance for the use of one of the DEA options in SCRIPT v10.6

See http://www.ncpdp.org/Resources/ePrescribing

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Long-Term Care Exemption Lifted Until November 1, 2014, entities transmitting prescriptions or prescription-related information where the prescriber is required by law to issue a prescription for a patient to a non-prescribing provider (such as a nursing facility) that in turn forwards the prescription to a dispenser are exempt from the requirement to use the NCPDP SCRIPT Standard adopted by this section in transmitting such prescriptions or prescription-related information. As of November 1, 2014, such entities will be required to use the adopted NCPCP SCRIPT standard(s). (42 CFR §423.160) • Final Rule published November 16, 2012 in Federal Register. See

http://www.gpo.gov/fdsys/pkg/FR-2012-11-16/pdf/2012-26900.pdf • Lifted the long-term care exemption • Finalization of NCPDP SCRIPT v10.6 requirement and

retiring of SCRIPT v8.1

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Who is Affected?

• Prescribers

• Pharmacies

• Long-Term Care Facilities

• Pharmacy Software Vendors

• EMR Software Vendors

• Intermediaries

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e-Prescribing in Long-Term Care

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A Brief History of the LTC Exemption

• Based on Public Comment in the 2004 NPRM

• LTC Community asked to be exempted

• Current e-Prescribing workflow would make it burdensome to the industry

• Pilot tested in 2006 in the LTC setting (SCRIPT 8.1)

• Results of Pilot finding - changes were made to subsequent versions of NCPDP SCRIPT (10.2 and Higher)to handle the LTC workflow

• July 2010 IFC -based on public comment CMS hinted at lifting the exemption at a later date.

• CY 2013 PFS – Based on industry comment CMS lifts the LTC exemption effective 11/1/14

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Physician Orders?

Are physician medication orders considered prescriptions or prescription-related information and therefore subject to e-Prescribing regulations?

Yes, a physician’s medication order serves as the patient’s prescription and is subject to the federal regulations regarding e-Prescribing.

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Point of Care to Dispenser?

Are verbal physician orders that are transcribed by a LTC facility into an LTC EMR/EHR system, then transmitted electronically to the dispenser subject to e-Prescribing regulations?

Yes, “E-prescribing includes, but is not limited to, two-way transmissions between the

point of care and the dispenser.”

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How is it Done Today?

• HL7 Messaging

• NCPDP SCRIPT*

• Computer-Generated Facsimile (CGF)

ALL EXCEPT NCPDP SCRIPT WILL BE NON-COMPLIANT SOLUTIONS

BEGINNING NOVEMBER 1st, 2014

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Alternatives to e-Prescribing

• Prescription Pad

• Telephone/Verbal Order from Prescriber to Dispenser

• Manual Fax

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Consequence of Non-Compliance

Everyone

– Administrative efficiency issues

– Reduced standards of care

– Non-compliance with regulatory requirements

Physician

– Lost incentive opportunities?

– Reimbursement penalties?

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Consequence of Non-Compliance

EMR Software Vendor

– Non-compliant customers = Dissatisfied customers

Pharmacy

– Reimbursement?

Long-Term Care Facility

– Financial responsibility?

– Resident’s financially responsible?

– Operational disruption due to reverting back to traditional alternatives

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Next Steps

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Next Steps Long-Term Care Facilities

– Reach out to your pharmacy and inquire about their readiness for e-Prescribing

– Reach out to your software vendor and inquire about their readiness for e-Prescribing

Software Vendors – Ensure that your system can send/receive SCRIPT v10.6 messages

beginning November 1st, 2014

Pharmacies – Ensure that you can accept SCRIPT v10.6 messaging from your

customers beginning November 1st, 2014

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Additional Resources

• Code of Federal Regulations (§423.159 & §423.160)

• Centers for Medicare and Medicaid Services (CMS)

• National Council for Prescription Drug Programs (NCPDP)

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Post-test Question

1. When is the current Exemption for Long-Term Care to use NCPDP SCRIPT to transmit electronic prescriptions for Medicare Part D set to expire?

a. July 1, 2014

b. November 1, 2014

c. October 1, 2014

d. January 1, 2015

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Post-test Answer

1. When is the current Exemption for Long-Term Care to use NCPDP SCRIPT to transmit electronic prescriptions for Medicare Part D set to expire?

a. July 1, 2014

b. November 1, 2014

c. October 1, 2014

d. January 1, 2015

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Post-test Question 2. Which of the following transaction standards

were named as Foundation Standards for the

Part D e-Prescribing program

a. NCPDP SCRIPT

b. NCPDP Telecommunication

c. NCPDP Medication History

d. ASC X12N 270/271

e. All of the above

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Post-test Answer 2. Which of the following transaction standards

were named as Foundation Standards for the

Part D e-Prescribing program

a. NCPDP SCRIPT

b. NCPDP Telecommunication

c. NCPDP Medication History

d. ASC X12N 270/271

e. All of the above

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Post-test Question

3. True or False: Once the exemption is lifted for LTC, Facilities will still be able to use HL7 messaging to transmitted electronic prescriptions for Part D eligible Beneficiaries

a. True

b. False

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Post-test Answer

3. True or False: Once the exemption is lifted for LTC, Facilities will still be able to use HL7 messaging to transmitted electronic prescriptions for Part D eligible Beneficiaries

a. True

b. False

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Post-test Question

4. Which of the following are NOT allowed under

the Part D e-Prescribing Program For LTC

a. Computer-Generated Facsimile

b. HL7 Messaging

c. NCPDP SCRIPT 10.6

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Post-test Answer

4. Which of the following are NOT allowed under

the Part D e-Prescribing Program For LTC

a. Computer-Generated Facsimile

b. HL7 Messaging

c. NCPDP SCRIPT 10.6

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Post-test Question

5. True or False: Are physician medication orders considered prescriptions or prescription-related information and therefore subject to e-Prescribing regulations?

a. True

b. False

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Post-test Answer

5. True or False: Are physician medication orders considered prescriptions or prescription-related information and therefore subject to e-Prescribing regulations?

a. True

b. False

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Questions?

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NCPDP Upcoming Webinars June 18th

Electronic Prior Authorization: Overcoming Adoption Barriers. An AMCP and NCPDP collaborative webinar. This webinar is only available to AMCP and/or NCPDP members.

June 19th-

XML: An Introduction. If you are implementing the NCPDP SCRIPT Standard transactions or Specialized Standard transactions it is important to understand how to read and interpret XML. This webinar will focus on use of XML in the information standards used in electronic prescribing and pharmacy information exchanges.

Future NCPDP Webinar Topics will include: Medicare Part A Changes to the Hospice Benefit, Specialty Pharmacy and more…

Visit: http://www.ncpdp.org/Education/Webinar