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A CCHIT Based Guide to a Qualified E-prescribing System – Part I (The 2008 requirements)

Posted: April 11th, 2009 | Author: | Filed under: Basics | Tags: , | 2 Comments »

As I mentioned briefly in my previous post, Medicare is providing incentives for practices to implement a “qualified” e-prescribing solution.  The Medicare Improvement for Patients and Providers Act of 2008 (referred to lovingly as MIPPA) describes in detail the schedule of payments for practices (found here), but it falls short on detailing what a qualified system is.  Instead, the Center for Medicare and Medicaid Services (CMS) points to certification authorities to provide the guidance of qualifying a practice’s system. As the Certification Commission for Healthcare Information Technology(CCHIT) will be the basis for the EHR incentives that come with the healthcare stimulus package, I thought it might be a good exercise to see what they had to say about e-prescribing.

I started by going to CCHIT and downloaded the final CCHIT Certified 08 Ambulatory EHR criteria and test scripts.  I then used the excel spreadsheet(CCHITCriteriaAMBULATORY08FINAL.xls)  and filtered by category “9. Medications / ePrescribing”.  For the sake of providing a foundational view of ePrescribing, I then further filtered my results to only include the 2008 provisions.  The list contained requirements that The table below illustrates my results:

IO-AM 09.02 The system shall provide the ability to display CCD documents, using a subset of the HITSP C32 specification for Allergy and Conditions content information, and file them as intact documents in the EHR
IO-AM 09.04 The system shall provide the ability to generate and format CCD documents with narrative sections and structured entries (discrete fields) as specified by the HITSP IS03/C32 specification of the Allergy and Conditions module subset. For 2008, the values within the structured entries do not have to use industry standard vocabularies/terminologies (such as RxNorm or SNOMED-CT)
IO-AM 09.06 The system shall provide the ability to send an electronic prescription to pharmacy
IO-AM 09.09 The system shall provide the ability to respond to a request for a refill sent from a pharmacy
IO-AM 09.13 The system shall provide the ability to send a query to verify prescription drug insurance eligibility and apply response to formulary and benefit files to determine coverage
IO-AM 09.14 The system shall provide the ability to capture and display formulary information from pharmacy or PBM (Pharmacy Benefits Manager) by applying eligibility response
IO-AM 09.15 The system shall provide the ability to send a query for medication history to PBM or pharmacy to capture and display medication list from the EHR

I was initially confused by the first two entries.  It makes sense that EHRs be able to handle incoming and generate codified Allergy and Conditions to help in safely ordering medications, but I want to focus strictly on ordering the medication in my EHR and getting that prescription to the pharmacy electronically.  The Continuity of Care Document (CCD) is a subject worthy of its own series of posts.

Once I remove the CCD requirements, there are really only five requirements to satisfy in order to claim victory for the 2008 requirement set.  It may seem simple enough, but to satisfy these requirements you will find that the ordering system your granddaddy used (from paper to even existing electronic ordering) will need to be changed considerably.

Stay Tuned

Now that we’ve looked at all that is required to be a qualified e-prescribing system in 2008 according to CCHIT, I plan on detailing what exactly this entails per requirement.  Eventually, I plan on catching us up to the present year by doing the same with the 2009 requirements.  After that, get your flux capacitors fluxing and we’ll even check out what the future holds for us (2010 and beyond).

2 Comments on “A CCHIT Based Guide to a Qualified E-prescribing System – Part I (The 2008 requirements)”

  1. 1 MI FARMACIA said at 12:36 pm on January 11th, 2010:


  2. 2 George Getty III said at 8:50 am on January 26th, 2010:

    Retail pharmacies need to work with SureScripts in order to receive new prescription requests and send refill requests to prescribers. SureScripts has designated this as “Routing Certification”. You can learn more about SureScripts here: http://www.surescripts.com/

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