Print this pageCaution urged in development of guidelines for electronic prescribing
Following is a sign-on letter in which SVS is a participant. The letter urges caution as guidelines for electronic prescribing are developed, as directed by the recently passed Medicare Modernization Act.
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May 18, 2004 John R. Lumpkin, M.D., M.P.H., Chair Dear Dr. Lumpkin: On behalf of the undersigned organizations we look forward to working with the National Committee on Vital and Health Statistics (NCVHS) in the development and implementation of electronic prescribing standards. During the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) debate, the physician community supported provisions to create uniform national standards to help facilitate the dissemination of electronic prescribing. We are hopeful electronic prescribing can achieve its promise of improving patient safety and increasing administrative efficiency. As you prepare your recommendations to the Department of Health and Human Services (HHS), we would appreciate your consideration of the following issues. Although the concept of electronic prescribing appears simple, broad scale electronic prescribing as defined in MMA barely exists in the ambulatory setting. Some hospitals and large practices can electronically communicate with on-site pharmacies via closed systems, but two-way, interoperable, and secure external systems currently are used only in extremely limited circumstances. Development of a single set of standards appropriate for all health care delivery situations will be a significant undertaking. From the physician perspective, standards for electronic prescribing must take into account the wide variety of clinical settings and specialties. We urge NCVHS to recommend standards that are flexible and scalable in an effort to encourage adoption from small to large health care organizations and low- to high-volume prescribing physician specialties. Core standards must allow for basic stand-alone electronic prescribing platforms that permit solo physicians or small practices to meet the regulatory requirements without an undue financial burden. The standards should also provide for the needs of larger, more complex group practices and health systems. This flexibility will allow physicians to consider critical factors such as clinical quality, safety, efficiency, and integration with existing management software and electronic medical record systems when making an investment. With each health care organization being unique, flexibility to customize and implement systems to scale is critical. Most importantly, the physician-patient relationship must be enhanced, not impaired by this new technology. Incorporating electronic health records and prescribing systems in the physician practice without disrupting patient care is critical. For physicians to widely adopt a new technology it must allow for a safer and more efficient way to treat patients. Whether it is new imaging technology or information technology, these principles remain constant. Moreover, time is a precious commodity for physicians, and standards for electronic prescribing must be developed in a manner to provide vendors with a platform to create technology solutions that save time for physicians and their staff. Time saved can be refocused on patient care, providing physicians with a tangible clinical and financial incentive for investment. Clinical quality improvement and patient safety are significant and important drivers for physician adoption of new technology. Information technology’s greatest potential lies in these areas and we believe electronic prescribing presents great promise for improved patient care. However, new technology must also be reliable. In the fall of 2003 a “significant and unforeseen” computer hardware failure in the Maryland Medicaid program left 1000 pharmacies without the ability to check eligibility, formulary and claim information, leaving prescriptions unfilled for several days. No technology is immune from failure. Standards must require fail-safes in any new system to prevent the introduction of new health care errors. Similarly, standards must be employed that minimize the electronic transmission of “false-positive” clinical information to physicians, such as clinically irrelevant drug-drug interaction alerts. As you advise HHS on electronic prescribing, we urge you to make recommendations in the context of lessons learned from implementing provisions of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act. A critical factor in the protracted implementation of the Electronic Transactions and Code Sets rule has been the inability of the provider community to upgrade their practice management and billing software in a timely manner. Delays in release of the standards coupled with inadequate vendor outreach by HHS clearly contributed to this problem. Vendors need to see a commitment by the government before creating or adapting existing systems to meet new standards. After the required pilot testing for electronic prescribing standards, HHS should release the final rule as quickly as possible to encourage vendors to update or bring products to market that assist physicians to comply with the statutory requirements ahead of the deadline. Staggered implementation dates should be considered as pharmacies and pharmacy benefit managers must have systems up and running to allow physicians to send test prescriptions that comply with new standards. Physicians must rely on their vendors to provide them with the tools necessary to comply with the electronic prescribing program. Strong government leadership is critical to rapid and seamless conversion. Finally, to successfully implement voluntary electronic prescribing in the Medicare program, NCVHS and HHS must be fully aware of the future Medicare environment. By law, electronic prescribing standards must be in place by April 1, 2009. At the same time, CMS actuaries predict approximately minus five percent reductions each year in Medicare reimbursements to physicians from 2006-2012 with a slightly lesser cut in 2013. Concurrent with these cuts, the costs to care for patients are likely to continue growing at a pace that exceeds inflation. This means that by 2014, after eight years of reductions, physicians will be paid about 40% less than in 2005, while practice costs will have increased significantly. Although matching grants have been authorized to help the adoption of electronic prescribing, funds have not yet been appropriated. In this financial environment it will be extremely difficult for physicians to allocate the resources necessary to invest in any new technology unless it provides an irrefutable, tangible benefit to their patients and practice. To this end, careful and deliberative standards development is critical to widespread adoption and achievement of electronic prescribing’s promise of improved efficiency, patient safety and health care quality. Again, we appreciate your consideration of the above mentioned issues and look forward to providing additional input as this process moves forward. Sincerely, American Academy of Dermatology Association |
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