For many years, ASCP and other pharmacy organizations have been advocating for the inclusion of pharmacist practitioners in new and existing health care delivery and payment models. Today, policymakers are seeking ways to revise the U.S. health care system to a sustainable higher-quality, lower-cost structure. To achieve this, the current system is transitioning away from fragmented episodic care with limited collaboration to patient-centered models expertly coordinated along a continuum of care.
Electronic health information technology (eHIT) is the foundation for achieving the higher levels of care coordination so critical to reaching national healthcare goals—and for ensuring the integration of pharmacist practitioners in this evolution of the healthcare system.
ASCP believes that eHIT must include the basic functions of pharmacist practitioners, which include but are not limited to: e-prescribing, the provision of cognitive clinical services (including medication therapy management), and providing immunizations. In order for pharmacists to be effective in delivering these services as part of the new standard of health care, pharmacists need to have the ability to access and contribute to relevant and patient-specific information found in electronic health records (EHRs). Pharmacists must also be able to document, in EHRs, the direct care they provide to patients, and they must be able to bill for those services regardless of the setting in which they practice.
ASCP is an active partner in a variety of eHIT-focused coalitions working with stakeholders and policymakers at national, state, and local levels to identify and advocate for opportunities to include Long Term and Post Acute Care (LTPAC) in health IT and innovation initiatives. These coalitions engage in information sharing, policy development, advocacy, and planning on behalf of many health professions and stakeholders:
The links below provide a comprehensive view of the issues surrounding eHIT, including policy and regulation updates, information and recent news about the requirement, and ASCP resources and products to help consultant pharmacists adopt and implement eHIT policies.
ASCP Policy Resources
Articles from The Consultant Pharmacist (you will need to log into the member section to view online)
eHIT Laws and Regulations
The Health Information Technology for Economic and Clinical Health (HITECH) Act, which was enacted as part of the American Recovery and Reinvestment Act (ARRA) of 2009, includes key provisions related to adoption and “meaningful use” of health information technology. HITECH authorizes CMS to provide reimbursement incentives for eligible professionals and hospitals that adopt certified EHR technology. Pharmacists were excluded from the list of eligible professionals. However pharmacists’ willingness to become meaningful users is key to advocacy for direct reimbursement for pharmacist-provided clinical services. The HITECH Act also includes an amendment that gives statutory guidance for managing the disclosure of patient health information contained in electronic health records and transmitted electronically.
Regulations for Meaningful Use
The regulations detailing criteria, requirements, and available incentives for the meaningful use of EHRs by eligible providers are segregated into three stages. Each stage will require increasing use of EHRs and electronic exchange of information in order to qualify for the reimbursement incentives. The final rule outlining eligibility for Stage 1 meaningful use incentives was finalized July 28, 2010 and is currently in effect. The final rule guiding participation in Stage 2 of meaningful use incentives was published in the September 4, 2012 issue of the Federal Register.
Affordable Care Act
Section 1561 of the Affordable Care Act, signed on March 23, 2010 by President Obama, required HHS, in consultation with the Health Information Technology (HIT) Policy Committee and the HIT Standards Committee, to develop interoperable and secure standards and protocols that facilitate electronic enrollment of individuals in Federal and State health and human services programs.
The HIT Policy and Standards Committees approved initial recommendations on August 19, 2010 and August 30, 2010, respectively. On September 17, 2010, Secretary Kathleen Sebelius adopted these recommendations with slight edits. These recommendations include initial standards and protocols that encourage adoption of modern electronic systems and processes that allow a consumer to seamlessly obtain and maintain the full range of available health coverage and other human services benefits.
Office of the National Coordinator for Health Information Technology Publishes a Federal Health IT Strategic Plan Through 2015
In March 2011, the federal Office of the National Coordinator (ONC) for Health Information Technology, under the Department of Health and Human Services, also published a Federal Health IT Strategic Plan as an expansion of the 2008 strategic plan. The plan focuses on implementation of HIT programs through 2015, in preparation for longer-term HIT implementation.
For more information on past policies and regulations, please visit the eHIT News Archive page.
ASCP and eHIT Coalition Resources and Activities
LTPAC HIT Summit
On June 22–24, 2014, AHIMA will host its 10th annual 2014 Long-Term and Post-Acute Care Health IT Summit in Baltimore, MD, and ASCP will participate as a collaborator in this noteworthy event.
Pharmacy e-Health Information Technology Collaborative Submits Comments to CMS on Proposed Rule on Stage 2 Meaningful Use Requirements—May 7, 2012
ASCP collaborated with the Pharmacy e-Health Information Technology Collaborative to submit comments to CMS. On March 7, 2012, CMS announced the availability of a proposed rule outlining Stage 2 meaningful use requirements. This proposal outlines new criteria needed to qualify for incentive payments, timeline changes and payment adjustments. It also includes recommendations for increasing the electronic capturing of health information in a structured format, as well as increasing the exchange of clinically relevant information between providers of care at care transitions.
Pharmacy e-HIT Collaborative Releases Roadmap Through 2014
—December 9, 2011
The Pharmacy e-HIT Collaborative, in which ASCP participates, published its roadmap in late 2011. This roadmap outlines priorities for the pharmacy profession’s participation in HIT implementation through 2014. It also provides guidance to other organizations, policymakers, HIT vendors, payers, and others involved with integrating pharmacies and pharmacists into a larger national HIT framework.
For more information on past ASCP and eHIT coalition activities, please visit the eHIT News Archive page.
CMS Resources and Activities
CMS Delays Third Stage of Meaningful Use Implementation
The Centers for Medicare and Medicaid Services (CMS) announced March 5 that the agency would delay its rulemaking implementing the third stage of meaningful use of electronic health records. However, existing implementation deadlines for ICD-10 of October 1, 2014 will remain in place. The agency aims to use this delay to examine implementation of existing stage two requirements for meaningful use.
CMS also published a request for information from stakeholders on a variety of issues relating to electronic health information technology. The comment deadline for this solicitation was April 21.
This announcement and solicitation for information was communicated in concert with the Office of the National Coordinator for Health Information Technology, the White House office tasked with managing the long-term growth of health IT. Both CMS and the Office of the National Coordinator indicated that their long-term goal is nationwide adoption of interoperable electronic health records to facilitate implementation of a variety of new care delivery and payment models, such as Accountable Care Organizations and patient-centered medical homes.
Stage 2 EHR and Meaningful Use Interim Final Rule Now Available
—December 3, 2012
On December 3, the Centers for Medicare and Medicaid (CMS) released an interim final rule which made changes to the Stage 2 electronic health records (EHR) meaningful use (MU) program. In the text, CMS updates standards and provides more flexibility by changing or exempting certain standards. Easing reporting standards, defining “users” as “unique users,” and alternative lab result reporting measures are also among the changes made. The rule was published in the Federal Register on December 7. (Get additional background on Meaningful Use here.)
CMS Publishes Final Rule on Medicare Part D e-Prescribing Foundation Standards—
May 16, 2012
CMS published a final rule on Medicare Part D e-Prescribing foundation standards. Updates that were included are: The National Council for Prescription Drug Programs Telecommunication Standard Specification, Version D, Release 0 for eligibility queries between dispensers and Part D sponsors; the Accredited Standards Committee X12N 270/271-Health Care Eligibility Benefit Inquiry and Response, Version 5010; For eligibility and benefits queries and responses between prescribers and Part D sponsors.
CMS Releases Final Rule on Changes to the Electronic Prescribing (eRx) Incentive Program for Medicare—
September 6, 2011
CMS released the final rule on changes to the Electronic Prescribing Incentive Program. This final rule the modifies eRx quality measure for certain reporting periods in the calendar year 2011, provides additional significant hardship exemption categories to request an exemption for 2012 eRX payment adjustment and lengthens the deadline to submit requests for consideration for the two significant hardship exemption categories for the 2012 eRx payment adjustment.
For more information on past CMS activities, please visit the eHIT News Archive page.
AHRQ Funds Study on Pharmacy HIT Effectiveness
In November, a study funded by the U.S. Department of Health and Human Services' Agency for Healthcare Research and Quality found that while both prescribers and pharmacies are enthusiastic about the potential for e-prescribing and health IT, these groups face serious barriers to realizing the full benefit of technology. The study, published in the Journal of the American Medical Informatics Association, focused on e-prescribing and found certain problems with the e-prescribing process. Physicians and pharmacists in the study reported encountering problems when using electronic prescriptions in concert with renewals, when interacting with mail-order pharmacies, and when physicians failed to specify certain things such as packaging and drug form. Pharmacies also reported that patient instructions often needed to be rewritten in order for patients to understand them. The study’s authors warned that these problems need to be addressed as use of e-prescribing in a variety of practice settings increases.
GAO Study on Health Care Delivery Supports Health IT
A 2010 GAO study (PDF) on health care delivery issues highlighted health IT as a vital component to improving access to care and outcomes for underserved populations in integrated delivery systems. The Health Care Safety Net Act of 2008 directed the Government Accountability Office to report on integrated health care delivery systems (IDS) that focus on underserved populations, facing economic, geographic, cultural, or linguistic barriers to care. According to the report, health systems’ use of electronic health records, e-prescribing and other technology facilitated patient care coordination, increased targeted interventions for high-risk patients, assisted with population-level disease management, and reduced medication problems and overall costs.
For more past studies on electronic health information technology, please visit the eHIT News Archive page.