Meaningful Use

Response to Medicare and Medicaid Programs; Electronic Health Record (EHR) Incentive Program-Stage 3 Notice of Proposed Rule Making

Surescripts comments on the Notice of Proposed Rule Making (NPRM) titled "Medicare and Medicaid Programs; Electronic Health Record (EHR) Incentive Program-Stage 3."

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Surescripts comments in response to the proposed rulemaking issued by CMS and ONC for Stage 2 of the Meaningful Use program.

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Response to Medicare and Medicaid Programs; Electronic Health Record Incentive Program-Stage 2 Notice of Proposed Rule Making (CMS-0440-P)

Surescripts' comments on the Notice of Proposed Rule Making (NPRM), "Medicare and Medicaid Programs; Electronic Health Record (EHR) Incentive Program," published by CMS in the Federal Register on January 13, 2010 [CMS-003-P].

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Letter to the Office of the National Coordinator for Health Information Technology (ONC) regarding Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology (RIN 0991-AB82)

Surescripts comments on the initial set of standards, implementation specifications, and certification criteria for electronic health record (EHR) technologies published in the Federal Register on March 7th 2012.

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Interoperability

Comments on the 2015 Interoperability Standards Advisory
Surescripts Comments on the ONC's 2015 Interoperability Standards Advisory

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Comments on “Connected Health and Care for the Nation.”
Surescripts’ comments on the ONC’s draft interoperability roadmap, “Connected Health and Care for the Nation”.

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PCAST Report
Surescripts' comments on the 2010 President's Council of Advisors on Science and Technology (PCAST) report, "Realizing the Full Potential of Health Information Technology to Improve Healthcare for Americans: The Path Forward".

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HITECH Provisions

Surescripts comments on proposed HITECH Privacy and Security Rule Modifications
Surescripts response to the notice of proposed rulemaking (NPRM) that the Department of Health and Human Services (HHS) published in the Federal Register, Volume 75, Number 134, beginning on page 40868 on July 14, 2010. The letter specifically responds to the HITECH Privacy and Security Rule Modifications.

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Surescripts comments to the Department of Health and Human Services HITECH Breach Notification Interim Final Rule
Surescripts response to the notice of proposed rulemaking (NPRM) regarding the HITECH Breach Notification Interim Final Rule.

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Controlled Substances

Industry letter of support for Every Prescription Conveyed Securely Act
We write to thank you for your leadership on the Every Prescription Conveyed Securely Act and urge your colleagues in Congress to support this vital legislation. The opioid crisis is devastating families and communities from coast to coast. In 2015, more than 33,000 Americans, according to the Centers for Disease Control, died as a result of the crisis, a number that is only growing.

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Surescripts Position on DEA Third Party Audit Requirements
Surescripts would like to take this opportunity to point out that neither the DEA's EPCS IFR, nor subsequent published guidance, requires end-user hospitals, physicians or pharmacies to have their security practices approved or participate in a security assessment.

Click here to read the full position statement from Surescripts

Surescripts EPCS Update to State Boards of Pharmacy
This is a memo sent to State Boards of Pharmacy, State Controlled Substance Agencies, and State and National Pharmacy Organizations as an update on industry progress in implementing electronic prescribing for controlled substances.

Click here to read the EPCS update letter.

Surescripts comments to the DEA Interim Final Rule on E-Prescribing for Controlled Substances
Surescripts applauds the publication of this groundbreaking Internal Final Rule (IFR), which we believe is a substantial step forward from the NPRM that the DEA published in the Federal Register in 2008.

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A Primer on Controlled Substances
by Ken Whittemore
To set the stage, a passage from the DEA's web site:

"Many of the narcotics, depressants and stimulants manufactured for legitimate medical use are subject to abuse, and have therefore been brought under legal control. The goal of controls is to ensure that these "controlled substances" are readily available for medical use, while preventing their distribution for illicit sale and abuse."

Click here to read the entire primer.

E-Prescribing and Healthcare Costs

Medication Affordability and Noncompliance
by Ken Majkowski

Numerous research studies have documented that many elderly and chronically ill do not get recommended care, fill prescriptions, adhere to their medication regimens or see a doctor when sick because of costs. Non-compliance with prescription medication causes an estimated 125,000 deaths annually and costs at least $75.6 billion each year. Other impacts include such adverse outcomes as avoidable hospitalization, development of complications, disease progression, and premature disability. These findings underscore the importance for patients in exploring lower cost options, including generics, mail-service pharmacies, and electronic prescribing.

Policymakers should explore cost-savings options, including accelerating adoption of waste-cutting health information technologies such as e-prescribing that alert patients and doctors alike when affordable choices are available.

Standards

Response to Medicare Program; Identification of Backward Compatible Version of Adopted Standard for E-Prescribing and the Medicare Prescription Drug Program (NCPDPSCRIPT 10.6) (RIN 0938-AP49)

This is Surescripts response to changes to the interim final rule of the National Council for the Prescription Drug Programs (NCPDP) Prescriber/ Pharmacist Interface SCRIPT standard.

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