David Lashar

This year, it is the day after Halloween that might be scary. On November 1, prescribers, pharmacies and facilities in the long-term-care industry must cease the transmission of electronic medication orders via the HL7 and e-fax methods that predominate today.

Per Centers for Medicare & Medicaid Services regulations, prescribers, pharmacies and facilities — and the technology vendors on whom they rely — must switch to a new transmission method, NCPDP SCRIPT 10.6 (SCRIPT), for medication orders to remain eligible for Medicare Part D reimbursement. Those who cannot transmit their electronic orders via SCRIPT on November 1 will need to revert to manual methods of transmission in order to be eligible for reimbursement.

If prescriber, pharmacy, facility and technology vendor have not all made successful transition to SCRIPT by the deadline, the fulfillment of patient prescriptions could be delayed or disrupted. This article summarizes steps that all parties in LTC should be taking in order to prevent that scary prospect from actually coming to be.

What is SCRIPT?

SCRIPT, like HL7, defines a structure by which the data relating to an electronic order is organized for transmission and processing.  SCRIPT, unlike HL7, is broadly used outside of LTC. The CMS goal with the November 1 deadline is to bring LTC into conformance with standards that prevail in the rest of the healthcare services industry.  To learn more about both SCRIPT and NCPDP, please see:  http://www.ncpdp.org or http://www.cms.gov/eprescribing .

Why should you care?

Whereas all HL7 and efax (i.e., computer-generated-fax or CGF) systems must be disabled by November 1, organizations need to be ready either for transition to SCRIPT or for reversion to manual fax for transmission of medication orders to their pharmacies.  And since relatively few technology vendors in LTC had deployed SCRIPT interfaces that were certified for production operation even as of late August, the prudent course for prescribers, pharmacies, and facilities is to prepare for reversion to manual fax, even if only as a contingency against the risks inherent in any major technology change.

Were the transition from HL7 to SCRIPT merely a technical exercise in mapping the information from one standard format to another, contingency planning would likely be all that was required.  The additional challenge is that the transition from HL7 to SCRIPT almost certainly necessitates changes in the workflow among prescribers, pharmacies and facilities.

Workflow changes will likely be needed, because the new SCRIPT standard does not support the data requirements of LTC as robustly as the established HL7 standard. As a result, even organizations at the forefront of the SCRIPT transition are, as of early September, unsure what will be required for fundamental LTC processes — such as communicating order directions, requesting refills, performing therapeutic interchange, and handling controlled substances — when the technology vendors update their EHR applications and interfaces to support SCRIPT. The vendors are working hard on figuring it out, but as of early fall, formidable questions remain.

What should you do?

Given the uncertainties about how SCRIPT will be enabled in systems, prescribers, pharmacies, and facilities should generally engage their technology vendors in a productive manner to ascertain plans and progress, while preparing to revert to manual fax as a contingency and planning to conduct training on the changes sure to come.

More specifically, prescribers, pharmacies and facilities should:

1.     Validate the plans of their technology partners for compliance with the SCRIPT standard (and conversion of legacy HL7 data, if needed) by November 1, seeking clarity on ways in which workflow may be affected.

2.     Confirm the contingency approach for sending medication orders to your pharmacy in the event that any of your partners are unable to meet the November 1 deadline for the SCRIPT standard. (The contingency will likely require manual faxing of orders, for example a manual fax of a hard-copy order that is either handwritten or printed by the EHR. The contingency may also require procedures for synchronizing the facility’s MAR with the pharmacy’s system of record.)

3.     Develop plans for (a) support from your own IT team, and (b) training to your own system users. 

4.     Consider postponing any HL7 or CGF implementations planned for this fall, until SCRIPT is validated as ready from your system vendor(s).

Whatever you do, do not underestimate the potential impact of this imminent change. If you prove not to be ready, this November 1 may come to haunt your memories.

David Lashar is CIO at Remedi SeniorCare.