In response to Joseph Conn's CMS to allow alternatives to tamper-proof paper":
As the speaker referenced at the Association of Medical Directors of Information Systems conference and one of the sources quoted in Mr. Conn's storyI am delighted that the collaboration of many stakeholdersled by the National Council for Prescription Drug Programs, or NCPDP, was able to make compliance with the Medicaid tamper-resistance law more reasonable and more effective for electronic health-record users who occasionally still have to print Medicaid prescriptions. As I made very clear during my talk, I could discuss the process and direction that our collaboration was going, but that public notification of that clarified guidance would come from the CMS and the NCPDPand not from my comments.
More importantly, while my colleagues might view an outcome that allows compliance with the tamper-resistance law to be achieved with printer-security solutions and not solely with tamper-resistant paper as "overturning" the CMS regulationsthis is a mischaracterization of the work and the collaboration that achieved it.
The Physicians' Electronic Health Record Coalition and the Electronic Health Record Vendors Association strongly support efforts that decrease the potential for prescription fraud and prescription forgery. We did not join with the NCPDP and the CMS to overturn anything; rather we believed that the law and the first set of regulations surrounding the law needed more clarityparticularly when applied to printed prescriptions from EHRs or electronic-prescribing applications.
The entire process was collaborative and fairwith all stakeholders having a shared vision of the regulations being clear, reasonable and effective. The physician EHR-user community and the EHR vendor community owe a debt of gratitude to the NCPDP and the CMS for their hard work on our behalf, and more importantly, on behalf of the American public.
Peter Basch, M.D.Medical directorAmbulatory Clinical SystemsMedStar HealthColumbia, Md. To submit a letter to YOUR VIEWS, click here. Please include your name, title and hometown.