February 1, 2010

Tom Sullivan, M.D.

Dear President Obama


Dear President Obama,
Thanks for the incentives, but can you help us make some progress with standardizing e-prescribing regulations too?

You, along with The Federal Government, have done an excellent job creating incentives for providers to adopt healthcare IT. Now we need you to help create a comprehensive and improved national standard for electronic prescribing.

Individual state variances currently prevent e-prescribing vendors and most clinical providers practicing near state borders from generating and utilizing valuable clinical enhancements nation-wide. These logistical road-blocks create a slippery slope for all stakeholders, increasing the financial burden of development and implementation as well as forcing vendors to chose between valuable clinical enhancements versus meeting the requirements of 50 different state certifications. This situation prevents the creation of cost-efficient e-prescribing (and other health IT) solutions.

The need for national e-prescribing standards is here. Uniform nation-wide, reasonable standards are poised to increase the adoption of e-prescribing by streamlining and improving 50 individual state rules regarding:

  • prescription format
  • special paper/forms and printed prescriptions
  • vendor certification requirements
  • variances of controlled drug schedules
    Example: Soma – a common muscle relaxant for lower back injuries – is a controlled drug in Texas
Examples of state-specific requirements:
  • Indiana
    • Only certain vendors can be used for generating prescriptions for controlled substances and those vendors have to generate the printed prescription as quarter-page size, with information that needs to be completed by hand.
  • Ohio
    • It has one of the most strict certification requirements, but does not publish a consolidated written implementation guide to help ensure that the requirements are met.
  • Maryland
    • Requires every vendor that generates electronic prescriptions to undergo 3rd party certifications. If different states require different certifications, this will be incredibly time consuming and expensive for vendors.

Finally, Mr. Obama, the Federal Government needs to legalize e-prescribing of controlled substances. Requiring a separate workflow for controlled drug prescriptions is hampering adoption of the healthcare IT you so strongly endorse, and for some providers has eliminated the desire to even try e-prescribing – let alone a broad health IT strategy. HHS and ONC support this change, but the Treasury Department (which manages the DEA) does not seem to be aware of the importance of this issue to advance health IT. Your directive to correct this would be a “Win-Win” for everyone.

You were out of the gate running with large incentives to help support the dissemination of “meaningful use” health IT, but the healthcare community needs you to continue pushing and facilitating adoption and enhancement at a national level.

Tom Sullivan, MD

About Tom Sullivan, M.D.

Thomas E. Sullivan, M.D is a board-certified specialist in cardiology and internal medicine with over 40 years of clinical practice. He currently works for DrFirst and sees patients part-time in Massachusetts. His expertise in the application of information technology to health care has helped to create an international standard (ASTM) for the exchange of medical record information called the Continuity of Care Record (CCR). With AMA, he was founding chair of their e-Medicine Advisory Committee, worked with the Physician Consortium for Performance Improvement, represented the AMA and helped create the Physician EHR Coalition and is past chair of the AMA Council on Medical Service.