The DEA has finally published its proposed rule to allow electronic prescribing of controlled substances. It is going to be interesting to see how the pharmacy and medical stakeholders respond. While the DEA is dropping the idea of PKI, in my opinion the alternative is not much better. What’s proposed will impose new burdens on prescribers and pharmacies. One is that pharmacies will need the pharmacy system initially audited by a third party for compliance. You will not be able to take your vendor’s word for it. Then there will be an annual audit required by a third party. Pharmacy is clearly looking at a new cost of doing business. I will not get into the other details here; these will be covered in the next issue.

There is increasing pressure from policy makers and legislators to accelerate the use of electronic prescriptions. Many see this as an important element of an electronic health record. The recent merger of RxHub and SureScripts is seen as a step to facilitating e-prescribing. Vendors of medical practice management and medical record systems would be dealing with one gateway for both the prescreening before prescribing and the actual electronic transmission of the prescription. There is some merit to this. I, however, am curious as to how this merger will work out over the long run. Here we have a PBM-backed operation on one hand (RxHub) getting together with a pharmacy-backed operation (SureScripts). These backers have not been the best of friends over the years. For that matter, SureScripts was formed to counter RxHub’s entry into electronic prescriptions. SureScripts was so effective in executing its business plan that RxHub had to back down and redefine its role. Now they have agreed to play together. Time will tell how this works out.

On another note, we have the IRS rule that requires a special product file in point-of-sale systems come January 1, in order to accept FSA and HRA debit cards. The responsibility for screening eligible medical care items that can be charged to these cards is being pushed down to the retail level. TPAs were spending too much time and money sorting through paper claims. Does this have a familiar ring to it? It should, since this is what the PBMs decided to do with prescription claims, when they implemented real-time systems. Not only did the PBMs also tap into the technology being used by pharmacies, but they then decided to levy a transaction charge to submit these claims. With the IRS ruling, this is also going to cost pharmacy money. Unless your pharmacy qualifies for the 90% exemption, you will have to join SIGIS in order to have access to the “approved” product file.

Pharmacy just keeps being forced to shoulder new costs. CT