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

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1 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:

2 Speaker Disclosure Andrew Morgan and Gary Schoettmer report no actual or potential conflicts of interest associated with this presentation

3 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: L04-P & L04-T

4 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.

5 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

6 Agenda e-prescribing Overview Regulatory Requirements e-prescribing in Long-Term Care Next Steps Questions 6

7 e-prescribing Overview 7

8 e-prescribing CMS Definition E-prescribing means the transmission using electronic media, of prescription or prescriptionrelated 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 ) 8

9 e-prescribing 9

10 e-prescribing using SCRIPT v

11 e-prescribing using SCRIPT v

12 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 12

13 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 13

14 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 14

15 Electronic Prescribing Use* e-prescription Routing increased 38% in % of prescriptions dispensed were routed electronically Prescription Benefit Responses increased 33% in % of visits generated an electronically delivered medication history * Surescripts 2012 National Progress Report on e-prescribing 15

16 Regulatory Requirements 16

17 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 January 2009 July 2010 November 2012 December 2013 CY 2009 Physicians Fee Schedule- lifted the exemption to the Computer Generated Fax (CGF) effective (1/1/12) CMS published HIPAA Modification Final Rule Updates to two Foundation Standards IFC to adopt NCPDP SCRIPT Standard version 10.6 on a voluntary basis. 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) CY 2014 Physicians Fee Schedule- adopted a newer version of the Formulary and Benefits Standard (3.0) effective (2/28/15) 17

18 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 18

19 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 19

20 Controlled Substances Final Rule: /pdf/ pdf The SCRIPT Implementation Recommendations Document contains guidance for the use of one of the DEA options in SCRIPT v10.6 See 20

21 Long-Term Care Exemption Lifted Until November 1, 2014, entities transmitting prescriptions or prescriptionrelated 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 ) Final Rule published November 16, 2012 in Federal Register. See Lifted the long-term care exemption Finalization of NCPDP SCRIPT v10.6 requirement and retiring of SCRIPT v8.1 21

22 Who is Affected? Prescribers Pharmacies Long-Term Care Facilities Pharmacy Software Vendors EMR Software Vendors Intermediaries 22

23 e-prescribing in Long-Term Care 23

24 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 24

25 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. 25

26 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. 26

27 How is it Done Today? HL7 Messaging NCPDP SCRIPT* Computer-Generated Facsimile (CGF) ALL EXCEPT NCPDP SCRIPT WILL BE NON-COMPLIANT SOLUTIONS BEGINNING NOVEMBER 1 st,

28 Alternatives to e-prescribing Prescription Pad Telephone/Verbal Order from Prescriber to Dispenser Manual Fax 28

29 Consequence of Non-Compliance Everyone Administrative efficiency issues Reduced standards of care Non-compliance with regulatory requirements Physician Lost incentive opportunities? Reimbursement penalties? 29

30 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 30

31 Next Steps 31

32 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 1 st, 2014 Pharmacies Ensure that you can accept SCRIPT v10.6 messaging from your customers beginning November 1 st,

33 Additional Resources Code of Federal Regulations ( & ) Centers for Medicare and Medicaid Services (CMS) National Council for Prescription Drug Programs (NCPDP) 33

34 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,

35 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,

36 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 36

37 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 37

38 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 38

39 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 39

40 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

41 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

42 Post-test Question 5. True or False: Are physician medication orders considered prescriptions or prescriptionrelated information and therefore subject to e-prescribing regulations? a. True b. False 42

43 Post-test Answer 5. True or False: Are physician medication orders considered prescriptions or prescriptionrelated information and therefore subject to e-prescribing regulations? a. True b. False 43

44 Questions? 44

45 NCPDP Upcoming Webinars June 18 th Electronic Prior Authorization: Overcoming Adoption Barriers. An AMCP and NCPDP collaborative webinar. This webinar is only available to AMCP and/or NCPDP members. June 19 th - 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: 45

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