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CMS-1403-FC We also received unsolicited comments on this issue during the comment period for the November 16, 2007 Part D e- prescribing proposed rule (proposing the adoption of certain final Part D e-prescribing standards and the use of NPI in Part D e-prescribing transactions) (72 FR 64900). As a result of the new information, we reexamined this issue and proposed additional modifications to the computer-generated facsimile exemption in the CY 2009 PFS proposed rule (73 FR 38502). Dispensers have indicated that they use computer-generated facsimiles for the majority of prescription refill requests, in particular when communicating with prescribers that have not adopted e-prescribing. Currently, regardless of how the initial prescription was received by the pharmacy (that is, orally, via e-prescribing, telephone, paper, or facsimile) nearly all prescription refill requests from chain pharmacies to prescribers are sent electronically, either via an e-prescribing application or via computer-generated facsimile. When a prescription is received by a dispenser electronically, the prescription refill request is sent to the prescriber via the same technology. However, where the dispenser knows that the prescriber lacks e-prescribing capability or has not activated it, or where the prescriber 332
CMS-1403-FC does not respond to the request sent to his or her prescribing device, the prescription refill request is sent or resent via computer-generated facsimile. Commenters stated that the vast majority of computer-generated facsimiles sent today from prescribers to pharmacies are not electronic data interchange (EDI) transmissions, but usually prescription refill requests sent from pharmacies to prescribers who do not conduct true e-prescribing and, in many cases, do not engage in any electronic transactions at all. One national drug store chain estimates that it produces approximately 150,000 computer-generated facsimile prescription refill requests every day. The workflow and process for filling prescriptions would be significantly disrupted if these computer-generated facsimile transmissions were prohibited. Dispensers and other staff would be forced to revert back to making phones calls or using a stand-alone facsimile machine to contact prescribers each time a refill is requested. Commenters indicated that not only would this be counterproductive to the advances and efficiencies made in pharmacy practice, it would impose an undue administrative burden on dispensing pharmacies and pharmacists. 333
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<strong>CMS</strong>-1403-FC<br />
does not respond to the request sent to his or her<br />
prescribing device, the prescription refill request is sent<br />
or resent via computer-generated facsimile. Commenters<br />
stated that the vast majority of computer-generated<br />
facsimiles sent today from prescribers to pharmacies are<br />
not electronic data interchange (EDI) transmissions, but<br />
usually prescription refill requests sent from pharmacies<br />
to prescribers who do not conduct true e-prescribing and,<br />
in many cases, do not engage in any electronic transactions<br />
at all. One national drug store chain estimates that it<br />
produces approximately 150,000 computer-generated facsimile<br />
prescription refill requests every day.<br />
The workflow and process for filling prescriptions<br />
would be significantly disrupted if these<br />
computer-generated facsimile transmissions were prohibited.<br />
Dispensers and other staff would be forced to revert back<br />
to making phones calls or using a stand-alone facsimile<br />
machine to contact prescribers each time a refill is<br />
requested. Commenters indicated that not only would this<br />
be counterproductive to the advances and efficiencies made<br />
in pharmacy practice, it would impose an undue<br />
administrative burden on dispensing pharmacies and<br />
pharmacists.<br />
333