Did I miss the earlier coverage? And some additional questions...

[Scott Serich]

I'm going back through my notes and trying figure out how this new "NCPDP SCRIPT" model arose and led to a vote so abruptly.  Did I miss it when it was covered earlier?

 

As best I can tell from the Wiki and my email records, it wasn't even introduced until the February 11 Initiative call, whereas the other three candidates have been under consideration since as long ago as the April 2012 Work Group finding (ref. slide 10 of the file "Analysis and Recommendations for PDMP-to-EHR Interface - Data Format.pdf").

 

Was I asleep at the switch with regard to this new option?  Or was it in fact not introduced until just a couple weeks ago?

 

Given my very busy day job (just like everybody else), I can't imagine that I'll have sufficient time before Wednesday to perform anything resembling due diligence (and that assumes that I'll have a reviewable copy of the specification in my hands soon).

 

Is there any way to postpone the vote?

 

Alternatively, if the State PDMP stakeholders feel comfortable that they sufficiently understand the NCPDP SCRIPT specification to make an intelligent vote already, I'll withdraw my request.

 

On a related note, whoever gave this spec a score of "2" on the PDMP Speed criterion, while giving the PMIX/NIEM option a "1" must know something about the State PDMP systems that I don't. In fact, if somebody could let me know which States *have* already implemented the SCRIPT spec, and which States have *not* already implemented the PMIX/NIEM spec, this info would be very helpful as well (thank you).

 

Thanks.

 

[Chad Garner]

Thank you, Scott for asking the questions that a lot of PMPs should be raising if they had the opportunity and the time to participate. Rather than have a disproportionate group of stakeholders voting on data standards that many of us have little or no knowledge of, wouldn't it make more sense to get organizations which represent each group of stakeholders together to study the materials available and see how they could apply to their membership? For example, the Alliance of State Prescription Monitoring Programs would be in a much better position to put together a technical team to study this and see which, if any states could support each format. As it stands, I believe so far two states have said they could support one of the two formats preferred by the ehr vendors. Scott has been involved in data exchanges involving PMPs for quite some time. The fact that he doesn't seem comfortable with the direction this is heading should be a cause for taking a closer look.

[Scott Serich]

Thanks for the clarification, Chad. So it sounds as if it's the case that the State PDMPs are not of a unanimous, like mind in believing that the current top candidate would represent a full consensus recommendation of the identified stakeholders. In that case, I'll leave my request on the table that the vote be postponed to allow more time for this new candidate specification to be examined and assessed.

Personally (not necessarily reflecting the opinion of IJIS or BJA), to say that I'm not comfortable with the direction the initiative has started heading is perhaps understating my concerns. There have been other discomforting events. For example, the scoring model assigned weights of "Very important" (=3) to EHR ease and speed of adoption, while assigning weights of "Less important" (=1) to PDMP ease and speed of adoption.

I can't find anywhere in the record indicating that any State PDMP concurred with this weighting scheme, which appears to be clearly biased against the State PDMPs. Maybe some or all of them did concur, and I just haven't found the right spot in the record yet. Can anybody help me find the correct location? Otherwise it seems peculiar that this scheme would go entirely unchallenged and casts doubt (in my mind) as to whether it is a legitimate reflection of consensus on behalf of one of the identified stakeholders.

It might also help all the participants to keep in mind that the identified State PDMP "stakeholder" is actually a loose community of participants representing 50 sovereign governments. The fact that, in the past, they have concurred on a common ASAP data model specification for reporting and a common PMIX/NIEM data model for interstate exchange is, at some level, quite an accomplishment for which they deserve credit rather than derision (ref. an earlier comment "Do you get points for being at the table?"). If the initiative wishes to claim "consensus" including a stakeholder identified as "State PDMPs," then the initiative probably *should* lose points for not have more State PDMPs at the table. It might even make sense to list them as 50 independent stakeholders.

Alternatively, the "State PDMPs" stakeholder could be removed from the list entirely and replaced by the Federal initiative sponsors. It might not be ideal, but it would probably better reflect the nature of the actual "consensus" being reached.

Cutting to the chase, at the end of the day, the State PDMPs are severely resource-starved. If the Federal Government or the EHR community wants them to adopt yet another exchange standard, this could be accomplished more readily if this desire were backed up by sustained funding to the States to meet the added burden. Consensus in the current initiative would clearly be desirable. But, frankly, the funding commitments (or lack thereof) may end up being more determinative of the eventual outcome.