Discussion of Work Group Recommendations: Data Format Standards

[Prescription Drug Monitoring Program]

Please use this area for discussions of the PDMP Phase 1 Work Group Recommendations for Data Format Standards.  We would like to reach consensus on a data format for sharing prescription information between a PDMP system and an EHR/HIE system, and focus on how to best serve the Healthcare Domain and Patient Quality of Care.

[Prescription Drug Monitoring Program]

(Posting this on behalf of Bill Lockwood of ASAP):

 

I wanted to get back to you with clarification on a few things regarding ASAP.

 

1. The statement was made that there are a variety of versions of the standard being used. This is not true. The vast majority of the states are either using 4.1 or 4.2 and the differences between the two are minor. I have also had word from several states that they are planning to move to 4.2 from earlier versions.

 

2. In the past it has been the policy to review the standard every two years to see where improvements were needed in order to increase the quality of the data reported. The last update was in September 2011, when we introduced 4.2. The forward of 4.2 explains the changes made to 4.1. Again, minor stuff, but important in improving data quality. There are no plans to publish a new version in the near future.

 

3. The ASAP standard is a standard, not a specification. State PMPs publish the specs on how they want the standard used. For example, some states may need data elements in the AIR segment, while other states may not. But all work within the standard, Codes cannot be added, field definitions cannot be changed, field lengths cannot be increased. I mention this because you referred to the ASAP standard in Monday's call as a specification.

 

4. Versions 4.1 and 4.2 can be used to submit prescription records in true real time, if a state so decides to support real-time capture at the time of prescription processing.

 

5. In addition to the ASAP standard used to report to PMPs, ASAP also developed a Zero Report standard, which is being used now in a few states, when no controlled substances were dispensed during the reporting cycle.  The other is an Error Report standard that states can used when there are problems with the prescription records received that must be corrected and resubmitted.

 

6. Our latest initiative, which we just wrapped up, is a new standard to allow bidirectional connectivity to PMPs. The attached press release explains the purpose and design of this standard. Work on the development spanned six months. Our workgroup had participation from 25 individuals representing a range of stakeholders, including a number of PMPs.

[John Poikonen]

As much as I love Bill L and have no opinion of Surescripts, there is a case to use the established standard already implemented with systems.  Unless of course, there is a compelling reason or lack of functionality in the existing standard.

On the EMR side:

Many (most) EMR currently have capabilities to use the Script/Surescript standard to pull in a patients medication profile. Utilizing current capabilities will increase adoption time dramatically.  I would be interesting in the delta and compelling reason for using ASAP in lieu of this standard already in place for EMRs.  Perhaps I am missing something.

On the Pharmacy side:

Pharmacy systems are not as entrenched with the Surescript profile standard or the Script prescription standard. Therefore pharmacy system vendors may have to build capabilities for incoming data with one Standard or another.  Submitting a dispensing event for real time support of the PMPs with the current claim Standard from NCPDP is not adequate.  Using the ASAP standard here makes a lot of sense.

On the PMP side:

Supporting one standard for outgoing data to EMRs and Pharmacies and another for incoming transactions (Pharmacy only) seems to me to be the preferred option.

The press release mentioned was not attached, so I will look to read and understand that as well.

Regards,

John Poikonen, Pharm.D.

[Chad Garner]

Bill Lockwood has done a great job at getting all of the stakeholders together to decide what fields are required to exchange data between PMPs and Pharmacies. Yes, states do implement ASAP in slightly different ways, but at the end of the day, if you just account for the entire standard, you should be okay. The only problem with the ASAP standard is that the X12 format that is used is quite cumbersome. 

The PMP community has spent a great amount of time and energy developing the PMIX IEPD, which is a NIEM (federal standard) conformant XML schema, to exchange data between PMP systems. All of the major PMP vendors have already developed this model. This schema was developed with the ASAP format as a guide - so we leveraged the great work that Bill has already done. The format can be used for data submissions or request response. It can also be easily extended to fit other needs. It is already being used in Ohio to allow hospital EMR systems to request prescription history reports in an automated, real-time fashion via a Health Information Exchange as well as directly with another EMR system used in local physicians' offices. Ohio is currently in the planning stages to do the same in pharmacies. I believe (although someone would have to verify) that the PMIX format is also being used in Indiana and Kansas to exchange data between their PMPs and local HIE's. So, if we're looking for a standards-based data format for exchanging prescription information, I don't think you have to look much further than the PMIX IEPD. It has already been developed, it's flexible, it's free, and it is already in use in multiple states across multiple sectors of the healthcare industry.

Chad Garner

Chief Technical Officer

Ohio State Board of Pharmacy

[Vickie]

I am very much in agreement that we should use the ASAP standard to retrieve PMP history. I have saw the latest implementation guide for the ASAP prescription monitoring program (Version 1 Release 1) for retrieving historical data. I think it is a good solution to use.  It makes sense from a consistency standpoint to retrieve PMP history using ASAP, which is the same that we use to transmit the data to the PDMPs.  If additional data was added to the current ASAP format for uploading data to the PDMPs, then it could be easily reciprocated by the same entity for the change to the historical feed if applicable.  If we introduce NIEMs or any other format, then we are adding another vendor/process/roll out to the mix.  I have worked for a pharmacy software vendor for 15+ years now, and I can't recall where we have ever mixed entity standards in the same business objective between the pharmacy and the vendor.  It would be like saying use NCPDP D.0 to transmit claims but use another format for the response.  Or use Script 10.6 to transmit prescription refill requests but another standard to accept a new rx.

 

On a side note, I am also a member of NCPDP, where issues such as these are addressed.  Wouldn't these questions be best answered with participation from NCPDP?  Members of NCPDP include prescribers, pharmacies, and software vendors.

 

[Prescription Drug Monitoring Program]

There is much good discussion here so far - thank you to all who have responded, and looking eagerly forward to more input from others as well.

 

As a reminder, we wanted to focus our initial efforts on reaching consensus on the format for data exchanged between a PDMP system and prescriber system, emphasizing the Healthcare Domain.

 

Could we also hear more feedback from various EHR systems vendors, users, etc. on existing HIE standards, and impacts of Meaningful Use requirements.  How can the PDMP community help to lower the barrier of entry for prescribers to use the data available?  What are the standards EHR systems can support?  What standards are already in place, and how does MU2 or MU3 affect plans for standards?

[Maria D Moen]

It appears that I just posted my reply in the wrong location, perhaps I need some standards brought to bear on my behalf?  :o)  Here goes again:

 

From a data format perspective, it is my opinion for LTPAC specifically, that there are two potential standards on the table and both are attractive from a vendor perspective and therefore, from a provider perspective.  The NCPDP SCRIPT 10.6+ formats incorporated the changes needed to address the specific nuances of LTPAC, and were called out in some legislation related to the ePrescribing exemption.  The HL7 data structures used currently by LTPAC to exchange data are another option, less rich in terms of messaging and quality of data exchanged, but more pervasive currently in terms of use.

 

There are a number of pharmacy interfaces in use by LTPAC across the country, some are proprietary and not standard and you know who you are, many are emerging that achieve some level of standardization through HL7 and less commonly, by NCPDP SCRIPT.  We prepared a position/comment letter to CMS less than 6 months ago and recommended that the NDPDP SCRIPT 10.6+ standards be part of lifting the exemption from LTPAC - this position was prepared by NASL and had the full cooperation and buy-in of many of our software vendors.  They are poised to integrate the new standard into their products, but as with most things in life, there needs to exist a compelling business case to take on the development cost.  And provider demand due to lifting the exemption qualifies nicely.

 

I look forward to discussions with this workgroup so that a cross-pollination between different perspectives can be brought to bear and we can all learn something from one another.