Letter to Nancy Johnson, Chair of the Ways and Means Health Subcommittee, in support of interoperability standards for e-prescribing & electronic health records

Dear Chairman Johnson:

As a follow-up to the Health Subcommittee’s July 22 hearing on e-prescribing, the Academy would like to assure you of our support of interoperability standards between electronic health records (EHR) systems and e-prescribing systems. The Medicare Modernization Act (MMA) (P.L. 108-173) includes provisions directing the National Committee on Vital and Health Statistics (NCVHS) to develop standards for e-prescribing. Representatives from the Academy’s Center for Health Information Technology have recently appeared twice before the NCVHS Security and Standards Subcommittee to testify on the importance of interoperability standards for e-prescribing and EHRs.

Family physicians place a high value on the interoperability of e-prescribing and a larger EHR because they usually serve as the patient’s ongoing source of medical care and coordinate referrals for subspecialist consultations, laboratory and diagnostic tests as well as manage prescriptions. Academy members are convinced that e-prescribing as a stand-alone application will be ineffective in reducing drug-to-drug interactions or inappropriate prescribing without the clinical decisionmaking support that an electronic health record (EHR) provides.

To be successful, e-prescribing must be integrated into the clinical workflow of a physician’s practice and allow the medical history information available from EHR systems to be readily available. A successful e-prescribing system must know a great deal about the patient besides what other prescription drugs have been prescribed. The best e-prescribing protocols comprise most of the data elements that form a summary of the electronic health record: patient demographics; problem list; allergies; side effects; lab test results and other elements of a patient’s medical history. Also, forcing data to be entered into two separate programs would hamper physician productivity. Therefore, the best solution is to integrate the e-prescribing function into every EHR system or build e-prescribing and EHR systems using interoperability standards. In this way, regardless of the order in which software programs are implemented, they can be integrated without disrupting the clinical work flow.

To achieve this goal, the Academy believes that any standards for e-prescribing must allow integration with existing and future EHR systems. Commonly agreed upon, non-proprietary, low-cost standards must be adopted for the exchange of clinical information between e-prescribing systems and EHR systems, whether these systems are implemented separately or concurrently. To achieve the goal of interoperability, data exchange standards should be accredited by the American National Standards Institute and be developed on a consensus basis.

The Academy has presented these concerns to the NCVHS and looks forward to continued work with the Security and Standards Subcommittee to ensure e-prescribing standards that maximize their ability to improve quality, utilization and patient safety.
The Academy also hopes to work with the Ways and Means Committee as it considers future health information technology issues.

Sincerely,

James C. Martin, M.D., FAAFP
Chair, Board of Directors