Washington University School of Medicine.--MO

Document ID: CMS-2011-0108-0012
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: June 01 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 8 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 1 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 25 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e390a9
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The rules regarding ePrescribing for Medicare/Medicaid are too restrictive, and not consistent with the way most physicians practice. When caring for chronic diseases, like hypertension, one prescribes refills as the patient runs out of medication, which is almost never on the day the patient is seen in clinic. The rules, as I understand them, are that ePrescribing only "counts" when it is done before midnight on the actual day the patient is seen in clinic. If I see a patient in clinic and they are doing well, I will not likely change their medications, and therefore there will be no need to ePrescribe that day. On the other hand, I typically ePrescribe standing medications between visits for my long-term patients, but this would not "count" according to the current rules. Another situation that would not lend itself well to an ePrescription on the day of the visit is the following (which happened to me last week with a Medicare patient): patient arrives for urgent visit at end of day. I listen to history, examine patient, and send them to laboratory and Xray to try to determine what might be going on. I do not wish to prescribe a medication such as an antibiotic until I see the laboratory results. However, the patient doesn't go to the lab until the next day. It clearly is in the best interest of the patient in most circumstances to await the laboratory results before ePrescribing something to treat them. A final situation is the following: A new Medicare Patient comes to clinic for consultation. The diagnosis is unclear, and I request outside records. It would not be appropriate for me to prescribe anything for this patient on their initial visit to me for a consultation.

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