Sunday, November 25, 2012

It Looks Like There Has Been Some Serious Movement on E-Prescribing and Script Exchange.

The following article appeared last week.

Script exchanges together

FRED IT’s eRx Script Exchange is set to become linked to rival MediSecure, with the government providing almost $10 million in funding to make the systems interoperable. According to an application revealed by the Australian Competition and Consumer Commission, the so-called ‘Electronic Transfer of Prescription (ETP) Prescription Exchange Service Interoperability Initiative’ aims to “significantly improve the uptake and use of electronic prescriptions”. E-prescribing is a significant policy component of the Fifth Community Pharmacy Agreement, and according to early analysis there are large numbers of electronic prescriptions being lodged by prescribers “ but the number being downloaded by dispensers is quite low” - due to patients presenting to a pharmacy which is not connected to the prescription exchange containing the e-script.
The project aims to allow electronic prescriptions to be accessed by all pharmacies, regardless of which exchange the script was lodged with. eRx and MediSecure are now tasked with working together and sharing all information necessary to create interoperability between their systems, with a deadline in the document of 24 Dec 2012 for the work to be completed.
The companies will each receive $660,000 (a total of $1.32m) as a capital contribution to undertake the work, which will also include the standardisation of the format and positioning of the barcodes on the original prescriptions.
Here is the information from the ACCC

eRx Script Exchange Pty Ltd - Authorisation - A91348

Applicant(s)
  • eRx Script Exchange Pty Ltd
Authorisation number(s)/Date lodged
  • A91348, 13th November 2012
Summary
eRx proposes to enter into a contract which has the purpose of enabling it to make its electronic pharmaceutical prescription exchange system (PES) interoperable with MediSecure's (MDS) PES and vice versa. Clause 14 of the proposed contract, which is the subject of this application, provides that following the introduction of interoperability, eRx and MDS will share equally in the fee which is charged to a pharmacy user and the Commonwealth by the PES to which the pharmacy is connected in respect of each prescription that has originated on the PES of the other party.
Documents
Here is the direct link to the application document:
The application is dated 9 November, 2012 but the funding arrangements (from the Commonwealth Department of Health and Ageing) were agreed months earlier.
It is interesting just how quickly approval was given.
It seems the two companies are going to have to get moving given the work to create the interoperability must be done by Christmas.
The Government is paying each of the Prescription Exchanges $660,000 as capital and then there is an amount of $8.3M available to be claimed as prescriptions are retrieved.
It is presently planned all the money will be claimed by June 30, 2013 via Medicare.
Pages 42-44 show the project timetable.
Pages 52 on describe the funded project. Here is the core of what is going on.

“C. The Commonwealth’s PES interoperability Project

The purpose of the Commonwealth’s PES Interoperability Project is to allow electronic prescriptions to be accessed by all pharmacies, no matter which PES the electronic prescription was originally lodged with. To achieve this outcome, the PESs must work together and share all information necessary to create interoperability between their systems to achieve interim interoperability4 by no later than 24 December 2012 in advance of conformance with Australian Technical Specifications for the Electronic Transfer of Prescriptions (ETP).
Full PES interoperability, conforming with Australian Technical Specifications for the Electronic Transfer of Prescriptions, and subsequent Australian Standards, will follow the completion of the Project.”
Obviously I am not very smart but I can’t find “Australian Technical Specifications for the Electronic Transfer of Prescriptions” on either the NEHTA or Standards Australia e-Health Web sites. Maybe they have a different name - but is it clear Standards Australia has still to approve the tech specs.
I have to say this all looks like a little of a mad rush to have something that will work available to satisfy ePIP requirements which are meant to be in place by February next year.
Oh well a little move forward!
David.

21 comments:

  1. I am really sick of the way these people throw money around in multi million dollar amounts. They virtually banned any work on the existing prescribing standards by standards Australia so that Nehta could bring down the CDA prescribing commandments from the NEHTA mountain. It seems that has fallen over, just like everything else Nehta touches and now they are going to create a pharmacy guild monopoly. Its not enough to pay them for every transaction, they want to pay them to do the work. So much for level playing fields.

    Its time the government got out of eHealth. They can't see a good standards based solution if they fell over it, but are taken in by every well funded snake oil salesman that arrives at their door, possibly bearing gifts? This is a disgrace.

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  2. It’s a bit of a long straw to say “this all looks like a little of a mad rush” when Annexure B shows that the funding agreement with the Commonwealth was signed 29 June 2012. Rather, I would suggest it is quite the contrary – not a mad rush at all – but a well planned, carefully considered strategy designed to solve the elusive issue of interoperability between two competing vendors.

    The fact that you have only just heard about it suggests it was more one of DOHA’s well kept secrets. All up it seems like an eminently sensible decision by DOHA to get two competing vendors to collaborate and compete with each other on a level playing field; something that until now NEHTA has DOHA have been unable to do. Perhaps you should rethink your views and dish out at few well deserved brownie points to DOHA on this one.

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  3. DoHA deserves zero credit. They have been messing about with e-prescribing for over a decade and were only forced into these steps after the private sector took their ball away and ran with it.

    They have utterly failed to properly manage and support this area in my view over a very long period of time.

    David.

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  4. David to say ‘DoHA deserves zero credit’ is quite unreasonable.

    Sure, “They – DOHA - have been messing about with e-prescribing for over a decade” and they have now seen the light and realised that without the skills and expertise of the private sector behind them they were not going to achieve anything. Plenty of people have been telling them that for many years and I believe you were one of them. No doubt NEHTA’s monumental incompetence has helped DOHA see the light.

    So DOHA took a very sensible pragmatic decision to get help to get it done and to underwrite the costs of doing so. You should give credit when credit’s due.

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  5. 650,000 dollars for each script exchange vendor to develop interoperability is a lot more realistic than the 15,000 dollars NEHTA is paying each messaging vendor to develop secure messaging interconnectivity.

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  6. David to say ‘DoHA deserves zero credit’ is unreasonable.

    Sure, “They – DOHA - have been messing about with e-prescribing for over a decade” and they have now seen the light and realised that without the skills and expertise of the private sector behind them they were not going to achieve anything. Plenty of people have been telling them that for many years and I believe you were one of them. No doubt NEHTA’s monumental incompetence has helped DOHA see the light.

    So DOHA took a very sensible pragmatic decision to get help to get it done and to underwrite the costs of doing so. You should give credit when credit’s due.

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  7. DOHA has made a serious investment in funding the script exchange vendors. No doubt its failed strategies of years past have driven the message home. You might want to give DOHA zero credit for past efforts but not to applaud them for pushing this very sensible interoperability initiative with script exchange vendors reeks of sour grapes undermining your objectivity.

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  8. Compared with the $800 million on the PCEHR this is chicken feed and they have ignored the problem for years.

    I first wrote a report to DoHA about all this in 1996 and they have messed it up ever since - utterly ignoring my advice and all other since.

    Remember we still have NEHTA / Standards Australia unable to even come up with a new ETP Specification after years.

    Damnation where it is due and these turkeys have really earned it.

    Show me the sensible policy statements that sorted it all out promptly after the KPMG Report and I might agree. It just never happened!

    This lot could not breath in an iron lung and why exactly did this take 6 months to become public?

    David.

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  9. BTW - So where exactly is the press release outlining what has been done? A secret?

    David.

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  10. Someone needs to explain to DOHA exactly what these mean:

    1. "openness" - Affording unobstructed entrance and exit; not shut or closed.

    2. "Integrity" - Steadfast adherence to a strict moral or ethical code.

    3. "Level playing field" - a situation in which none of the competing parties has an advantage at the outset of a competitive activity

    Its clear that they have no idea about any of these terms, not to mention the role of standards. I know human intelligence peaked 2 to 6 millennia ago, but I am shocked at how far its fallen since.

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  11. " No doubt[DOHA's] its failed strategies of years past have driven the message home… but not to applaud them for pushing this very sensible interoperability initiative with script exchange vendors reeks of sour grapes undermining your objectivity."

    Wow - where have you been in the last decade - certainly not in the ehealth arena. The point is that DOHA, through not basing decisions on advice from experts and the wealth of knowledge and initiatives already in place, wasted a lot of money and lost a lot of time. We could have had a very effective, value for money national e-medication system in place, but instead they got distracted by the expensive and so far useless PCEHRasaurus. Yes those grapes are very sour!

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  12. 1. ETP 1.1 is at http://www.nehta.gov.au/e-communications-in-practice/emedication-management
    The documents are prefaced with a comment that they are for information only and that a new revision will be available in the 2nd half of 2012.

    2. It appears we have two Prescription Exchanges each serving a number of prescribers and dispensers via its own proprietary protocol. The two exchanges are required to achieve "interim interoperability" (whatever that means) by Christmas Eve "in advance of conformance with Australian Technical Specifications for the Electronic Transfer of Prescriptions (ETP)" i.e. they have to achieve interoperability even though no standard exists yet, but they wil be expected to conform to one when it exists. It all sounds highly improbable to me.

    3. Electronic copies of prescriptions are still optional. While this remains the case some of the expected benefits of electronic prescribing cannot be achieved. True electronic prescriptions are not likely while we have a "Clayton's" NASH and no widespread distribution of individual PKI certificates.

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  13. If you believe in Santa and the Tooth Fairy, then it is not too hard to wish for "interim interoperability" for Christmas. Don't be so PESimistic!

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  14. We will never know how they interoperate as DOHA will have allowed a "Commercial in Confidence" standard to be created. Really anyone suggesting that DOHA should be applauded for doing this are setting the goverance bar pretty low. This is a disaster!

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  15. So if the GP creates a script and it is sent to the MDS PES (and printed out for the patient with the bar code), then the patient takes their paper script with the bar code to the Pharmacy, and the pharmacy system scans the bar code and then queries the eRX PES, then the eRX PES doesn't find it, then it will go and ask the MDS PES - which will hand it over to the eRX PES. Then the repeats will be stored I presume on the eRX PES. So all this fuss and bother of 'interoperability' between the eRX PES and the MDS PES will cost 1.2 million to develop. I do hope we are going to stop at 2 PESs. If someone builds a third PES, then my goodness, we will need a super-PES-hub to keep them all in synch. Not to mention the calculations to work out who gets what portion of the transaction fee. What an almighty mess! And here's the funny thing - we still have to have a paper script printed for each and every script and repeat!

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  16. Keith it is my understanding that MediSecure complies with the Australian Standard AS 4700.3 Part 3: Electronic messages for the exchange of information on drug prescriptions and that this is the basis of DOHAs interoperability initiative. Refer to http://www.e-health.standards.org.au/Home/Publications.aspx

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  17. > I do hope we are going to stop at 2 PESs.
    > If someone builds a third PES, then my
    > goodness, we will need a super-PES-hub
    > to keep them all in synch.

    Aha! Now you're on to something.

    The real reason why NEHTA and DoHA can't get an open interoperable ETP spec to be accepted. Because an open ETP spec would tend towards a solution state either involving ONE PES (the just do it once but do it well approach), or MANY hubs (lets have lots of competition to keep everyone on their toes approach).

    What it won't do of course is tend towards a solution involving exactly TWO hubs run ONLY by the guild and quasi RACGP. And funnily enough that is the state that the current players are most interested in.

    Now it looks like they are going to get paid to further entrench the duopoly, whilst the OPEN INTEROPERABLE part gets kicked further down the road. What's the bet that the existing PES vendor interest in an Australian Standard wanes remarkably quickly once their cosy little arrangement is completed.

    Nothing about ETP is technical - everything is political.

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  18. Does the Guild's eRx comply with the Australian Standard AS 4700.3 Part 3:?

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  19. 11/29/2012 09:38:00 AM said If someone builds a third PES ..... everything is political.

    The barriers to entry in this space are so high as to prohibit the entry of a third PES. As a pragmatist I say let's work with what we have available today.

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  20. The 'technical' barriers to entry for running a PES based on an OPEN specification are virtually nothing (other than implementing the spec and quite frankly - this is not exactly rocket science - it's uploading and downloading small well-defined packets of data).

    The barriers to entry are huge if you have to go vendor to vendor asking them to support your non-open PES at the GP/dispensing client end. But now that the two existing PES's have done exactly that, I would suggest that their interest in an open specification implemented equally by all GP/dispensing vendors is next to none exactly BECAUSE it reduces the barriers to entry. And it's fine they take that position, they did the hard yards in the first place. But let's not pretend there is not a fair bit of self interest in making sure nothing open happens in this space. Not everything is DoHA/NEHTA incompetence.

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  21. Dr Ian Colclough said...

    Keith it is my understanding that MediSecure complies with the Australian Standard AS 4700.3 Part 3: Electronic messages for the exchange of information on drug prescriptions and that this is the basis of DOHAs interoperability initiative. Refer to http://www.e-health.standards.org.au/Home/Publications.aspx

    Thanks, Ian. The full title of the standard appears to be "AS 4700.3(Int)-2007
    Implementation of Health Level Seven (HL7) Version 2.5 - Electronic messages for exchange of information on drug prescription" and it has an expiry date of 23 Nov 2011, whatever that means. I'm not sure how much this standard covers and how it relates to the ETP 1.1 specifications on NEHTA's website, but I suspect that AS 4700.3 relates only to message formats, not the communications protocol, which I surmise is still proprietary. Perhaps a more knowledgeable reader of this blog could clarify?

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