AAHKS commented on the Centers for Medicare & Medicaid (CMS) proposed rule to modify requirements for use of the HIPAA National Council for Prescription Drug Programs (NCPDP) D.0 Standard. The proposed rule “would adopt a modification to the requirements for the use of the Telecommunication Standard Implementation Guide, Version D, Release 0 (Version D.0), August 2007, National Council for Prescription Drug Programs by requiring covered entities to use the Quantity Prescribed (460-ET) field for retail pharmacy transactions for Schedule II drugs. The modification would enable covered entities to clearly distinguish whether a prescription is a ‘partial fill,’ where less than the full amount prescribed is dispensed, or a refill, in the HIPAA retail pharmacy transactions. We believe this modification is important to ensure information is available to help prevent impermissible refills of Schedule II drugs, which would help to address the public health concerns associated with prescription drug abuse in the United States.”

AAHKS supports CMS efforts to provide health care stakeholders the ability to clarify the dispensed amounts of Schedule II drugs through the requirement of the Quantity Prescribed field because the proposed rule enables health plans pharmacies to accurately reflect prescription fills and therefore create a complete picture of patient pain management, and compliance with the proposed rule does not increase administrative burdens for stakeholders. For more information, read the comment letter.