Basically
the HIPAA requires pharmacists to ensure that patients have actually
read the privacy policy of the pharmacy and have signed a log book
verifying this fact.
The log book system has been in vogue for some time in America,
and has been utilised for patients requiring counselling with their
prescriptions, and a necessary requirement for insurance companies
who may be paying for a counselling service.
Strict audit requirements by insurance companies has meant that
a considerable amount of time and stress is involved in maintaining
a satisfactory standard of accounting within the log book system,
which is mostly a paper-based system.
Formal
privacy policies in Australian pharmacies are mostly limited to
a handful of e-commerce Internet operators, who have developed
basic policies to illustrate to their clients that they are serious
in protecting confidentiality.
Few pharmacists have actually developed a written privacy policy.
This is not to say that Australian pharmacists do not embrace
privacy concepts.
They do, and very successfully, for there has been little consumer
complaint in this area.
This does not mean that privacy gaps have been eliminated---there
are still a few glaring examples, particularly at the point where
a patient is receiving their script, and some counselling may
be in progress. I have witnessed HIV medications being placed
on a bench in full view of all persons at a prescription collection
point, with the patient then proceeding to receive counselling.
And all this from the outpatient department of a public hospital!
American
experience in maintaining a log book in a busy pharmacy environment
is similar to some Australian experiences felt in administering
the Pharmaceutical Benefits Scheme (PBS). The expectations imposed
by regulators, developed in their environment, do not match the
practicality of the existing coalface of a pharmacy
environment.
This translates to errors and a high rate of claims being rejected.
It further translates to a sharp increase in overheads, a loss
of cash flow, and a correction workflow that is extremely costly
and unproductive (as well as being personally stressful).
The process is eventually corrected through some innovative pharmacist
taking time out to think through an out of the square
solution, generally at his or her own expense.
The American experience in having to sign up patients has now
been resolved through a system innovation called E-Sign,
which has implications for Australian pharmacy.
It involves the use of an electronic keypad to overcome the problem.
It is a device where basic patient data can be captured and coupled
to an encrypted electronic signature unique for each patient.
There are spaces for the patient to tick that they have read privacy
policy and have received counselling, and the data generated is
then transmitted to the dispense program forming part of the dispense
database.
The
good news is that the E-Sign hardware and program is inexpensive
and will interface with all popular dispense systems.
I
could not help thinking how this system might speed up all the
data collection required by the Health Insurance Commission (HIC)
and eliminate the problem of paper-based prescriptions floating
around the pharmacy awaiting patient signature.
The process looks like it could be incorporated in the Better
Medication Management System (BMMS) as a very worthy addition,
and the HIC would then have a very easy method of determining
who signed what and where in their searchable database.
The E-Sign system could also be easily developed to cope with
the Medicare numbers, Concession card numbers etc with the whole
process enabling patients to verify their details while the pharmacist
is dispensing their prescription unhindered.
Because all this detail can be tied to individual prescriptions
and transmitted electronically in claims, it has the potential
to reduce workload, claim rejections and stress, because the input
can be managed through pharmacy assistants, freeing up valuable
pharmacist time where previously, pharmacist intervention may
have been required.
The HIPAA legislation being enacted in America involves hefty
fines if signatures are not collected against a privacy policy.
The E-Sign system virtually eliminates this as a potential problem.
(The old log book system allowed other patients to see what previous
patients had signed for, but this is not possible with the E-Sign
system.)
The
E-Sign system has become so popular that some American pharmacists
have coupled it with an automated dispensing unit, and the company
driving most of this innovation is ScriptPro.
My only reservation is that by developing a system to solve a
host of government regulation requirements, it will be targeted
by future bureaucrats as a means of obtaining ever more detail
about patients and their prescriptions (at pharmacist expense,
of course).
Given the multi-million dollar budget of the HIC now, one has
to continually question why all this detail is necessary, and
does it save on cost?
I know the political reason for all this, but is it the real reason?
Last
month I wrote about another innovation called TrialCard, that
involved pharmacists in the ethical distribution of drug sample
packs. The patient details and the drug sample details are stored
on smartcards, and a claim is submitted to each manufacturer for
reimbursement.
Perhaps some Australian entrepreneur can devise something similar
to E-Sign that can capture data in multiple ways and provide a
universal mini-gateway system to deliver information to appropriate
organisations (including manufacturers,health funds and the HIC),
eliminating paperwork along the way.
To
read my previous articles on Australian pharmacy practice, please
click on this link.
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