e-Prescribing

NASL 2019 Issue Briefs:

What is e-prescribing?
The Centers for Medicare & Medicaid Services (CMS) defines e-prescribing as “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 also “includes, but is not limited to, two-way transmissions between the point of care and the dispenser.”(42 CFR §423.159) In 2005, CMS’ e-Prescribing Rule was implemented, mandating the use of the NCPDP SCRIPT Standard for all electronic prescriptions payable under Medicare Part D.


Exemptions to the e-Prescribing Rule 
Both the “LTC” settings, i.e., “...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…,” and Computer-Generated Faxes (CGFs) were exempt from the initial rule. The CGF or eFax exemption was removed by CMS as of January 1, 2012 and the LTC exemption was lifted as of November 1, 2014. The only remaining exemption to the e-Prescribing Rule is for the "Same Legal Entity." This exemption does not require use of the Part D e-prescribing standard for electronic messaging that is sent within the “same legal entity.” For example, if both a nursing facility and pharmacy are part of the same legal entity, then the rule allows either HL7 or NCPDP SCRIPT messaging to be used for internal electronic prescription transmittals.

NCPDP SCRIPT 10.6 Mandate
e-Prescribing remains voluntary. The e-Prescribing Rule does NOT mandate the use of e-prescribing; however, it does require the use of the NCPDP SCRIPT Standard for those who prescribe electronically. As of November 1, 2014, any electronic transmission of prescription or prescription-related information between a prescriber, a nursing facility and a dispenser must use the official Part D message standard – NCPDP SCRIPT version 10.6 (NCPDP 10.6). Because e-prescribing remains voluntary, covered entities may continue to participate in manual prescribing, which is reimbursed under Medicare Part D program (i.e., either hand-written or printed to paper from the facility’s EMR system). 


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