Surescripts recently announced that the NCPDP SCRIPT version 2017071 will become the mandated standard in order to maintain compliance and avoid transaction rejections. This mandate is officially effective September 1st, 2021. But what does this mean for small practices that may not have sophisticated tech teams to manage and keep abreast of these changes for their health IT systems?
Let’s make sense of this version upgrade, and provide you the information you need to stay compliant and continue to operate at peak effectiveness.
What is the NCPDP SCRIPT Standard v 2017071?
This new software standard is quite a mouthful. Let’s take it piece by piece to better understand the changes that will occur.
NCPDP (The National Council for Prescription Drug Programs) is a not-for-profit organization whose purpose is to standardize the exchange of health care information in order to improve outcomes, while also decreasing costs.
The NCPDP has developed a software script standard to facilitate the transfer of prescription data between pharmacies, prescribers, intermediaries, facilities, and payers. This script is used by many players in the prescription and pharmacy industry, and it’s incredibly important for everyone to be working from the same, most up-to-date version to keep information flowing as it should. For example, CMS has already adopted this script update as the official Medicare Part D prescription drug benefit e-prescribing standard.
How is the new NCPDP SCRIPT Standard different? Why does it matter?
NCPDP’s SCRIPT Version 2017071 includes important functionality and transactions identified by the industry as vital enhancements in improving patient safety, clinical decision-making, and business and administrative efficiencies for all stakeholders – and for the ultimate benefit of patients and healthcare providers.
The enhancements this new script version bring to the table include:
- Support for the electronic transmission of compound information, including ingredients and their quantities.
- Support for both veterinarian and non-veterinarian prescribers.
- Support for the reporting of allergies and adverse events.
- Support for the sending of laboratory testing dates and values.
- Directions for use now allow 1,000 characters and are included in the Sig element of SigText.
- Support for the inclusion of IV administration information, wound care information, and MTM services for specialty.
- Support for grouping of multiple prescriptions allowing for items like multiple dispensing and administration locations (such as school and home), injectable or IV medication, and associated supplies.
- Support for including diabetic supply information on a new prescription.
- Support for the sending of facility specific hours of administration for long-term care medication orders.
- Prescribers can choose when and if they want to receive the RxFill notification message based on the medication and the patient.
- The medication history response transaction has been enhanced to return data from Prescription Drug Monitoring Program (PDMP) administrators.
- Enhancements to digital signatures, as required for the electronic prescribing of controlled substance medications.
- Support for flavoring and the number of packages in which the medication is dispensed.
- Support for the manufacturer name, lot number, and expiration date of the product.
SCRIPT Version 2017071 also contains electronic prior authorization (ePA) transactions, as well as transactions for new prescription requests, transfers, and Risk Evaluation and Mitigation Strategy (REMS) request and response.
“NCPDP’s SCRIPT Standard supports a tremendous breadth of functionality to improve administrative efficiencies and patient care,” said Lee Ann Stember, President and CEO of NCPDP. “Implemented fully, SCRIPT gives providers actionable clinical data, within their existing workflows, for better informed clinical decision-making for the ultimate benefit of patients.”
When does the SCRIPT Standard update go into effect?
With an original implementation date of January 01, 2020, the NCPDP SCRIPT Standard update will now be effective as of September 01, 2021. According to Surescripts, “If any organization does not complete their migration by this new sunset date, their end-users may need to revert to paper or faxing prescriptions which may prohibit them from being able to prescribe controlled substances given that certain laws require e-prescribing of controlled substances.”
Prescribers, especially those in fields that commonly require the prescribing of controlled substances, will need to be working with a compliant system by the September 1st implementation date in order to continue business as usual.
How can I get up-to-date?
The fact of the matter is, all prescribers need to be working on a compliant system by the September 1st deadline. For EHRs, this means working with an e-prescribe partner to help keep prescribing technology up to speed. For smaller practices and single prescribers who may not use a full-fledged EHR system, this means onboarding a direct log-in e-prescribe tool as soon as possible.
We know. It’s difficult to keep abreast of the ever-changing regulatory landscape, especially if your primary focus is treating patients. That’s why NewCrop is here to help. Contact us today to schedule a demo of our e-prescribe system and learn more about direct log-in options to help you be prepared for the update.
What to Expect During DEA Audits
As an EHR vendor whose prescribers depend on you for prescription services, your product is subject to scrutiny by the DEA. Moreover, you have to ensure that your software complies with the Controlled Substances Act (CSA) to avoid punitive actions by the DEA. Typically, these audits occur every two years.
Below is an outline of what to expect during the audit process:
Request for Informed Consent
Most often, a DEA audit begins with the issuance of DEA form 82 which requests permission for the DEA to assess your practice’s documentation without using a search warrant. However, there are scenarios when the process begins with the issuance of an administrative search warrant. In such a scenario, the DEA won’t have to seek your consent to conduct the audit. Additionally, suppose the DEA is seeking to conduct an audit that pertains to a wider criminal investigation, the DEA will have to obtain a judicial search warrant to search your premises. Depending on the results of the audit, you risk losing your medical license, denial or loss of DEA registration, and federal prosecution.
Request for Billing Files and Patient Records
Upon gaining lawful access to your premises, DEA investigators will thoroughly examine your practices documentation and billing files to determine whether there are any discrepancies. You should expect the review process to be invasive and take a considerable amount of time. Given what’s at stake during this process, it may be prudent to seek legal advice to ensure that your rights are not infringed.
Examination of Your Prescription Drug Practices
Expect the DEA to closely scrutinize your drug prescription practices to make sure that it is in order. If the DEA finds any evidence of prescription fraud or drug diversion, you’ll probably find your practice facing criminal charges.
Request for Voluntary Surrender of Your DEA Registration
There are instances when the DEA will request that you voluntarily surrender your registration without issuing you with a formal evidence-based revocation. Again, while it’s in your best interest to comply with the request, you should seek legal representation to ensure that your rights are not infringed.
Issuance of an Order to Show Cause
Suppose the purpose of the audit pertains to an application for DEA registration, upon completion of its audit, the DEA may issue you with an Order to Show Cause. If you receive this Order, you’ll need to apply for a show cause hearing. If the hearing rules in your favor, then well and good. However, if you get an unfavorable determination, it’s recommended that you file an appeal if you want to stand a chance of prescribing or dispensing controlled substances in your practice.
Issuance of Audit Report of Noncompliance
Suppose the DEA finds that your practice violates the Controlled Substances Act (CSA), it will issue you with a noncompliance audit report that informs you of all the ways your practice violated the CSA. Getting this report probably means that your practice made grievous violations. As such, your practice may be subjected to further investigations by the Department of Justice (DOJ).
Investigations Regarding Healthcare Fraud
Suppose your practice has made serious CSA violations, the chances are that the DEA will elevate the audit of your practice to a criminal investigation. In such a case, it may be prudent to get yourself an attorney to help you navigate the process.
Third-Party Audits and Noncompliance
Now that we’ve outlined what you should expect from a DEA EPCS audit, what happens when you fail the audit process? If your organization fails to comply with any of the regulations mentioned above, your EPCS certificate will be nullified until you restore your compliance. Also, your organization may incur penalties that could amount to thousands of dollars.
The foolproof way of ensuring that you are compliant is by partnering with a compliant e-prescribe vendor and actively communicating with them throughout the partnership. Be sure to check that a vendor’s third-party audits are in order before deciding to work with them.
At NewCrop, we’re dedicated to supporting our EHR partners through the entire EPCS security and audit process. To learn more about how we can remove some of this burden from your team, schedule a demo today.