The CMS Proposed Update to NCPDP SCRIPT: Let’s Talk Timing and Consistency

In late November, the Centers for Medicare and Medicaid Services (CMS) proposed a new rule that calls for an update to the electronic prescribing standards used by the prescribers, pharmacies, their software vendors and Medicare Part D prescription drug plans who serve Medicare beneficiaries.

Surescripts believes the agency’s proposed rule to move to the next version of the National Council for Prescription Drug Programs (NCPDP) SCRIPT Standard is long overdue and will enhance the use, efficiency and accuracy of e-prescribing for millions of Medicare beneficiaries in a multitude of ways. But we also think that the timing of the implementation and the transactions included in the new standard should be thoughtfully reviewed. Earlier this month, we shared our thoughts about this critical effort with CMS, in which we emphasized two broad concerns:

1. While we strongly agree with CMS’s proposal that the healthcare industry move to the newest version of NCPDP SCRIPT as soon as possible, we don’t believe it’s realistic to expect this change to be implemented by January 1, 2019. Given our experience in implementing previous versions of NCPDP SCRIPT, and guiding hundreds of entities connected to our network through the process, we recommend that CMS adopt the updated version no sooner than 24 months after the date of the final rule on this proposal.
2. For reasons of consistency, efficiency and accuracy we recommend that CMS adopt the current NCPDP naming conventions for all transactions, that medication history, electronic prior authorization and resupply transactions be included in the list of transactions for the updated version of the NCPDP SCRIPT, and that the obsolete password change transaction be removed.

As the nation’s leading health information network, Surescripts transmits nearly 12.8 billion transactions annually, including nearly 4.8 million e-prescriptions daily. Today, our network connects virtually all electronic health record companies (EHRs), pharmacy benefit managers (PBMs), pharmacies and clinicians, plus health plans, long-term and post-acute care and specialty pharmacy organizations. We call this powerful collaboration, whose shared goals include increasing patient safety, reducing cost and increasing quality, the Surescripts Network Alliance.

A key priority of the Surescripts Network Alliance is to advance healthcare by enhancing and promoting the use of standards such as NCPDP SCRIPT. To further increase prescription accuracy, we must drive consistent application and adoption of best practices and agreed-to standards across the industry. Surescripts looks forward to continuing our engagement with CMS as the agency works towards improving the essential electronic prescribing standards encompassed by NCPDP SCRIPT.

To read more of our comments on the timing and implementation of the updated NCPDP SCRIPT Standard, please read our letter to CMS.