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Every year, hundreds of thousands of patients experience an adverse reaction or health complication resulting from prescription errors.

But with the rise of electronic prescribing, healthcare providers are now in a position to enhance how doctors and pharmacists deliver pharmacological therapy, improve patient outcomes, and lower expenses across the industry.

Through our collaboration with Surescripts, MEDHOST is committed to enhancing the accuracy of e-prescriptions for the benefit of physicians, pharmacists, and patients.

Enhancing e-Prescription Practices

Nearly two billion e-prescriptions pass through the Surescripts network annually.

Each is assessed for accuracy and given additional support through quality benchmarks and continuous reporting. Health systems, retailers, mail-order pharmacies, and electronic health records (EHR) companies like MEDHOST can use these indicators to identify issue areas and implement fixes based on actionable intelligence.

Greater Accuracy

There are more than 800 distinct ways to write "take one tablet by mouth two times daily," which means there are hundreds of ways to confuse a patient and cause an incorrect dosage. For pharmacists, the variety of pharmaceutical delivery methods, such as tablets, pills, and packages, make it possible to prescribe the right medication in the wrong potency.

By delivering clear instructions, Surescripts ensures a quicker and more accurate treatment process.

For instance, standardizing language (Structured and Codified Sig) aids patients with easy-to-read directions that are free of medical abbreviations or jargon, while appropriate Potency Unit Code (PUC) aids pharmacists in understanding prescriber intent.

Additionally, mismatched drug descriptions and IDs, such as National Drug Code (NDC) and RxNorm, can result in significant patient safety concerns. Using Surescripts’s ability to identify these differences, MEDHOST can upgrade pharmacy systems so that drug descriptions and NDC identifiers match, ensuring the proper alerts are triggered if a medication error occurs.

Less Administrative Burden

By enabling prescribers to replace or change prescriptions from within the MEDHOST EHR workflow, Surescripts also helps decrease administrative hassles and improve operational efficiency.

To streamline communication with prescribers, pharmacists can now electronically request changes to prescriptions within their workflow, while EPCS (Electronic Prescribing for Controlled Substances) guarantees that all prescriptions, including those for opioids, follow a single, effective e-prescribing procedure.

Best of all, the need for phone calls or faxes is eliminated thanks to Surescripts's accurate and up-to-date directory data feed to MEDHOST.

A Dedicated Partner

For many years, Surescripts has concentrated on filling prescriptions in a reliable, safe, and efficient manner.

To improve patient care by increasing the accuracy and efficiency of e-prescribing, MEDHOST and Surescripts's relationship helps bring together the expertise of hundreds of people from EHR vendors, pharmacies, pharmacy benefits managers, health systems, and drug companies.

Please contact us at inquiries@medhost.com or dial 1.800.383.6278 to find out how e-prescribing might increase prescription accuracy and medication adherence rates at your facility.

About Surescripts

Surescripts’s purpose is to serve the nation with the single most trusted and capable health information network, built to increase patient safety, lower costs and ensure quality care. Since 2001, Surescripts has led the movement to turn data into actionable intelligence and convened the Surescripts Network Alliance® to enhance prescribing, inform care decisions and advance the healthcare industry.

Public Health Reporting requirements on conditions specified by The Centers for Disease Control (CDC), The Centers for Medicaid and Medicare (CMS), and other related healthcare organizations have been part of Promoting Interoperability (PI)—formerly known as Meaningful Use1—since its inception. While public health reporting requirements have changed throughout program iterations, it was likely that some requirements would become obsolete around 2019.  

However, along with other considerations, the onset of the COVID-19 pandemic amplified the value in electronic reporting, resulting in a volte-face in CMS’ stand around the need for its continued use and certification. As part of the 2022 Inpatient Prospective Payment System (IPPS) rule, CMS mandated that health care facilities participating in PI must report for at least 90 days in Calendar Year 2022 (CY2022) on the following to qualify for federal healthcare incentives and avoid penalties. 

Why Mandate Electronic Case Reporting for Public Health? 

In mandating electronic case reporting on these specified conditions, CMS hopes to improve monitoring for public health emergencies while simultaneously providing a pathway for speedier and more efficient responses to such outbreaks.  

While there are no specific content exchange standards per the regulation, the mandate will require:  

What eCR 2022 Means for Healthcare Providers 

One of the main challenges this mandate presents to the facilities is short on-boarding time. The quick turnaround needed to meet a CY2022 deadline is further complicated when considering state-specific variations in their ability to accept case reports. 

How MEDHOST Helps Hospitals Prepare 

MEDHOST has supported the capability to report on the first three requirements (immunization registries, syndromic surveillance, and reportable lab tests and values/results) since the onset of the Meaningful Use Program. To ensure customers meet the program’s requirements, MEDHOST is also introducing support for 170.315 (f)(5) – Transmission to public health agencies – electronic case reporting.  

In its current state, the MEDHOST Electronic Case Reporting solution features: 

In keeping with MEDHOST’s endeavors to offer the best solutions to our customers, the MEDHOST 2022 R1 release will support the eCR Now application that will rely on FHIR integration. eCR is now a recommended solution from the ONC as a standardized mechanism of case reporting and will keep our customers on par with the industry. This integration will be available for adoption in CY2022 and is a MEDHOST best practice recommendation. 

To address any concern over the 90-day reporting requirement in CY2022, MEDHOST is offering this functionality in MEDHOST Enterprise 2021 R1 by modifying the Continuity of Care Document (CCD) to include information on reportable conditions. The functionality will also exist to maintain the list of reportable conditions automatically. 

To learn more about ECR and this critical Promoting Interoperability capability, please reach out to your Customer Success Executive or inquiries@medhost.com 

1 MEDHOST Enterprise 2019 R1, The Business Intelligence v5.5, MEDHOST EDIS 2019 R1 MEDHOST Enterprise, The Business Intelligence, MEDHOST EDIS 1 and MEDHOST Cloud Services Patient Portal with YourCareEverywhere ® App products and MEDHOST Cloud Services API are ONC 2015 Edition-compliant and have been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of the US Department of Health and Human Services. This certification does not represent an endorsement by the US Department of Health and Human Services or guarantee the receipt of incentive payments. For a complete review of the EHR certification and accompanying "Cost and Limitations" statements, visit https://www.medhost.com/about-us/regulatory-and-compliance/"https://www.medhost.com/about-us/regulatory-and-compliance/.  

A version of this article was originally published by our ePCS (electronic prescribing of controlled substances) partner, Surescripts.

Our partnership with Surescripts plays a critical role in helping our hospital customers remain compliant with several healthcare IT-related regulations.

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As Congress reconvenes in Washington this week, here are six healthcare regulatory and policy issues we’re keeping our eyes on. We hope this primer will help demystify the state of the health IT regulatory environment and give readers a deeper understanding of the impact and import of this activity.

  1. The 21st Century Cures Act, Interoperability and Patient Access Rules

The gist: In 2020, the Department of Health and Human Services (HHS) issued two related rules to implement the 21st Century Cures Act to encourage interoperability among health information technology systems, improve patient access to their health care information, and discourage practices that unreasonably prevent the access, exchange or use of such information. These rules, among many other things:

Background: The intent of these rules is to address concerns that healthcare organizations may make it unnecessarily difficult for patients and providers to obtain electronic health information, whether it's upon a patient's request, or for purposes already permitted under applicable law, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Status: These rules are in effect. We expect the HHS Office of Inspector General (OIG) to release its final rule regarding the enforcement of the information blocking provision early this year.

2. The Trusted Exchange Framework and Common Agreement (TEFCA)

The gist: TEFCA is intended to establish the infrastructure model and the governing approach for users in different networks to securely share basic clinical information with each other—all under commonly agreed-to expectations and rules. In August 2019, the Office of the National Coordinator for Health Information Technology (ONC) awarded a cooperative agreement to The Sequoia Project to serve as the Recognized Coordinating Entity (RCE) to administer a new nationwide network based on the Common Agreement. Visit ONC’s TEFCA website for more detail.

Status: The RCE recently finalized the common agreement,  standard operating procedures as well as the Qualified Health Information Network (QHIN) technical framework. ONC expects to begin reviewing QHIN applications and onboarding QHINs to the network by the second half of 2022.

3. HIPAA Notice of Proposed Rule Making and Care Management

The gist: The current HIPAA regulation limits the ability to access protected health information (PHI) for purposes of care coordination and case management with entities that are not health care providers. HHS is looking to change that. The HIPAA Notice of Proposed Rule Making modifies the current regulation in order to support individuals' engagement in their health care, remove barriers to coordinated care, and decrease regulatory burdens on health care providers and health plans.

More background: These modifications address impediments to the transition to value-based health care by limiting or discouraging care coordination and care management communications among individuals and covered entities (including hospitals, physicians, and other health care providers, payers, and insurers) or posing other unnecessary burdens. The NPRM includes proposals to address these burdens while continuing to protect the privacy and security of individuals' PHI.

Status: This is a proposed rule, pending the publication of a final rule by the HHS Office of Civil Rights.

  1. Real-Time Prescription Benefit Tools

The gist: The Consolidated Appropriations Act of 2020 included three provisions aimed at accelerating adoption and use of a real-time benefit tool (RTBT) for prescription drugs by 1) requiring that all Part D insurers provide for a RTBT that enables electronic transmission of eligibility, formulary and benefit information to each enrollee’s prescribing clinician; (2) adding use of a RTBT to the Merit-Based Incentive Payment System (MIPS) measures, and (3) requiring qualified EHRs under the ONC Health IT Certification Program to include a RTBT that conveys patient-specific cost and coverage information.

Status: The requirement on Part D plans was implemented on January 1, 2021. The second provision regarding MIPS took effect January 1, 2022. However, HHS’ implementation of the third provision, which requires qualified EHRs to include RTBT functionality that conveys patient-specific cost and coverage information, has been delayed. The delay is due to the requirement that rulemaking be conducted by CMS and ONC prior to implementation We don’t expect rulemaking to be complete before the third quarter of 2022 at the earliest.

Context and commentary: The requirement that insurers make an RTBT available in the Part D context is already in place. Surescripts Real-Time Prescription Benefit enables prescribers to be compliant with these legislative and regulatory actions. As of October, more than 550,000 prescribers were using Real-Time Prescription Benefit, which speaks to the technology’s utility and value. This year, we also expanded the reach of Real-Time Prescription Benefit among pharmacy benefit managers and health plans, covering more than 97% of U.S. patients in October 2021, up from 82% in 2020.

  1. Electronic Prior Authorization Requirement

The gist: On Dec 31, 2020, CMS issued a final rule that, for the first time, requires Part D prescription drug plans and prescribers to support a new electronic prior authorization transaction standard for their Part D e-prescribing programs. The rule, which has an effective date of January 1, 2022, but allowed plans to begin adopting it on January 1, 2021, also requires Part D plans to adopt NCPDP SCRIPT standard v2017071.

Status: This rule took effect on January 1, 2022 and adoption is underway.

Context and commentary: We are glad that CMS has recognized the value of the NCPDP standard for electronic prior authorization by mandating it for the patient populations they serve, specifically those in Medicare Part D plans and prescribers. Surescripts Electronic Prior Authorization utilizes NCPDP SCRIPT standard v2017071.

  1. EPCS Federal Mandate

The gist: On December 1, 2020, CMS announced in a final rule its decision to require that Part D providers use e-prescribing of controlled substances (EPCS) effective January 1, 2021. The rule implements a provision of the SUPPORT for Patients and Communities Act, which became law in 2018.

Status: While the rule is in effect, CMS has delayed the start date for compliance actions by one year to January 1, 2023. The start date for compliance actions for Part D prescriptions written for beneficiaries in long-term care facilities has also been delayed to January 1, 2025. CMS will initially enforce compliance by sending compliance letters to prescribers violating the EPCS mandate.

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In partnership with Surescripts, MEDHOST is dedicated to helping hospitals across the nation remain in compliance with new healthcare IT regulations, optimize patient care, maximize reimbursements, and avoid penalties.

To learn more about how we can support your hospital reach out to us at inquiries@medhost.com or call 1.800.383.6278.

This article originally appeared on WoltersKluwer.com. It is reprinted with permission. For more articles like this, visit Wolters Kluwer Health Expert Insights. 

Any clinician who has a role in medication therapy is affected by allergen screening. Until the advent of electronic health records (EHR), allergen screening was performed manually. 

With the widespread adoption of EHRs, embedded drug allergy screening has been well incorporated and has significantly improved medication therapy safety. But there are ways to further optimize screening to improve the sensitivity and effectiveness of alerts. 

Common scenarios in which potential allergen interactions need to be considered include: 

However, drug allergy screening is not limited to specific sectors. It impacts a wide range of healthcare roles and areas including hospice, home healthcare, and imaging/radiology, just to name a few. 

In some scenarios, along with an increase in patient safety, we have also seen an increase in undesirable alerts leading to alert fatigue. One cause of this rise in irrelevant EHR notifications is that non-specific or broad drug concepts, which can include unintended ingredients, are being used during the allergen selection process. By employing best practices and optimizing the capabilities of drug data and EHR software, the sensitivity of allergen screening can be improved to enhance patient outcomes and reduce alert fatigue. 

Challenges to Effective Drug Screening 

Two common medication concepts that are used in practice and lead to alert fatigue are NDC and Drug Name. 

Using the NDC, or packaged drug concept, to post patient allergens can lead to several issues: 

The Drug Name concept was designed as a grouping concept used to identify collections of drugs or health-related items. It is independent of route, strength, and dosage form and not directly linked to a specific active ingredient. Whereas the Drug Name concept seems to be a good choice when posting allergens, its use can also lead to alert fatigue: 

Is there a better way to improve drug allergen screening? 

Organizations can employ best practices when setting up allergen screening that can help improve its effectiveness. 

Allergen picklists 

An allergen picklist provides clinicians with medication names that are linked to the best concept for allergen screening. It is also designed to give clinicians a concise search that reduces duplicative or confusing drug names. The most effective allergen picklists contain common generic names with allergenic potential, select trade names associated with minimal inactive ingredients, select allergen classes, and some inactive ingredients if they are proven to have significant allergic potential (e.g., peanut-containing drugs). 

EHR inputs 

Some inputs incorporated into the EHR may be helpful in addition to screening. These could include: 

Medical conditions can be associated with allergens to record reactions and give further context to clinicians. A clinician-assigned designation of allergy versus an adverse drug reaction or intolerance can also be included. For example, anaphylaxis is an allergic reaction, compared to nausea, which a patient may call an allergic reaction, but is more appropriately defined as an ADE or intolerance. 

Timing and overrides 

Best practices also include performing allergen screening early in the medication order entry process. This design allows the clinician to be alerted before taking further, time-consuming steps. 

Allergy alerts should be allowed to be overridden with the opportunity or requirement for the clinician to document a reason. If possible, this override message should be displayed to subsequent users. For example, if a physician overrides an allergy in an EHR, the recorded override reason should be passed to the pharmacist at order verification and the nurse at administration. 

NKDA 

An option to enter No Known Drug Allergies, or “NKDA,” should be easily accessible to the end user. One convenient method to achieve this is adding a one-click NKDA radio button close to the search bar. 

Allowing other options, such as “Unknown” or “Not available at this time,” is debatable. It may be beneficial in some scenarios, such as an emergency room where a patient may be admitted unconscious or confused. However, offering a prompt to the clinician to update allergens when additional information is available has the potential to create obstacles. 

Free-text allergen input should only be allowed after all search options have been exhausted. Free-text allergens will not screen because they are not linked to an ingredient in the system’s data. Therefore, it is always recommended to incorporate extra steps for the user before they are permitted to enter a free-text allergen. Also, free-text entries should be easily identifiable in the patient’s profile. This might include displaying the allergen in a different colored text or marking it with an indicator such as an asterisk. These easily recognizable free-text entries should also include a general disclaimer, so all clinicians are aware they are unscreenable allergens and manual screening is required. 

It is worthwhile to speak with your implementation specialist or customer support department for more information about ways you could optimize drug allergy data and screening within your EHR. 

Please note: All these recommendations apply to drug allergen screening in the U.S. International best practice recommendations may differ. Consult your implementation specialist for additional considerations. 

It’s tough to measure the accuracy and quality of paper prescriptions. But thanks to the innovation of electronic prescribing, we can now track medications digitally to see gaps and errors more clearly.

Simply put, e-prescribing has changed the way clinicians, pharmacists, and patients administer drug therapy—and we are now poised to fully leverage this technology to improve quality and reduce costs in healthcare.

However, challenges remain. Each new prescription transaction involves various elements. If not appropriately coordinated, these elements can affect patient safety, add administrative burden, and cause delays in getting medications into patients’ hands. All these obstacles can add up quickly and cause patients not to take the needed medication as intended.

Medication nonadherence alone creates up to $290 billion in avoidable healthcare costs in the U.S. each year. Pharmacists and healthcare experts have also expressed concerns that the recent COVID-19 pandemic will only make medication nonadherence a more significant problem.

We must reduce the error rate and improve efficiency in e-prescribing. Doing so will significantly improve the healthcare system’s operational performance by streamlining workflows and clarifying prescriber intent.

Through our partnership with Surescripts, MEDHOST is committed to improving e-prescription accuracy for the benefit of prescribers, pharmacists, and, most importantly, patients.

Improving the Practice of e-Prescribing

According to Surescripts, nearly two billion e-prescriptions travel across their network every year. Each e-prescription is measured for accuracy and further supplemented with quality benchmarks and reporting. These metrics provide actionable intelligence to health systems, retailers, mail-order pharmacists, and electronic health records (EHR) vendors like MEDHOST, enabling them to effectively identify problem areas and make corrections.

Surescripts has increased the accuracy of e-prescription transactions by more than 80 percent since 2016 by eliminating errors, inconsistencies, and incompleteness. In addition, they have also increased the adoption of enhanced transaction types, improving alignments with the Surescripts directory.

Error Reduction:

Mismatched drug descriptions and identifiers, such as National Drug Code (NDC) and RxNorm, put patient safety at risk. Surescripts’ ability to pinpoint these discrepancies enables MEDHOST to update their systems and ensure drug descriptions and NDC identifiers match.

Reduced Administrative Burden:

“Take one tablet by mouth two times daily” can be written in more than 800 different ways, confusing the patient, who may take the wrong dose. To further complicate matters, medications come in various forms—tablets, pills, packages—so it can be difficult for pharmacists to know the prescriber's intent.

Standardizing language (Structured and Codified Sig) helps patients avoid adverse health events and reduces the administrative burden for those working within the MEDHOST e-prescription platform. An Appropriate Potency Unit Code (PUC) built into the Surescripts integration also helps pharmacists understand prescriber intent: not one package, but one tablet, for example.

The end result: clear directions and increased speed to therapy.

Improved Efficiency:

Surescripts also helps reduce administrative burdens and increase operational efficiency by allowing prescribers to replace or modify prescriptions from inside their MEDHOST EHR workflow—rather than making phone calls and sending faxes to pharmacies.

Pharmacists can also make modification requests to prescriptions electronically and within their workflow, streamlining communication with prescribers.

In addition, EPCS (Electronic Prescribing for Controlled Substances) ensures a single, efficient e-prescribing workflow for all prescriptions, including opioid prescriptions.

More Digital, Less Paper:

An up-to-date and accurate directory data feed to MEDHOST from Surescripts helps to ensure that e-prescriptions are sent efficiently, without the need for phone calls and faxes. Surescripts assesses the alignment of 10 key prescriber fields in their directory and is working to increase the use of the Learning Directory among EHRs and pharmacies.

The Path To Progress

For years the industry’s focus was on moving prescriptions efficiently, safely, and reliably.

MEDHOST and Surescripts’ partnership helps bring together hundreds of individuals representing EHR vendors, pharmacies, pharmacy benefits managers, health systems, and drug compendia to improve patient care by enhancing e-prescribing accuracy and efficiency.

To learn how e-prescribing can help improve the accuracy of prescriptions and medication adherence rates at your facility, please reach out to us at inquiries@medhost.com or call 1.800.383.6278.

 

About Surescripts

Surescripts’ purpose is to serve the nation with the single most trusted and capable health information network, built to increase patient safety, lower costs and ensure quality care. Since 2001, Surescripts has led the movement to turn data into actionable intelligence, and convened the Surescripts Network Alliance® to enhance prescribing, inform care decisions and advance the healthcare industry.

Opioid analgesics are FDA-approved prescription medications that can provide pain control for moderate to severe pain when appropriately prescribed; however, inappropriate prescribing can lead to opioid abuse, diversion, and deadly overdoses.1

According to the Centers for Disease Control and Prevention (CDC), the number of drug overdose deaths was four times higher in 2018 than in 1999 despite a recent decrease and, of those 67,367 deaths in 2018, nearly 70 percent involved an opioid and 14 percent involved prescription opioids. As stated by the CDC, “the best ways to prevent opioid overdose deaths are to improve opioid prescribing, reduce exposure to opioids, prevent misuse, and treat opioid use disorder.”2

Benefits of Electronic Prescribing of Controlled Substances

Electronic prescribing of controlled substances (EPCS) allows physicians to transmit controlled substance prescriptions securely to their patient’s pharmacy. The use of EPCS reduces prescription fraud and diversion by removing the risk of prescription forgery and alterations. It also decreases prescribing errors that are often caused by illegible handwriting and use of unapproved abbreviations. And, because the electronic prescription data flows into state prescription drug monitoring program (PDMP) databases, EPCS can help provide physicians with insight into a patient’s controlled substance prescription history, thus helping to identify “doctor shopping” behaviors and opioid overuse.3

Current Usage and Future Requirements

EPCS is now legal in all fifty states, yet it is not widely adopted. Less than 60 percent of all United States prescribers are currently EPCS-enabled, despite having 96 percent of US retail pharmacies capable of receiving electronic controlled substance prescriptions.4 However, individual state and federal regulations will soon change that.

The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act, passed by Congress in 2018 to help combat the opioid crisis, requires EPCS for all controlled substances prescriptions covered under a Medicare Part D prescription drug plan or Medicare Advantage Prescription Drug (MA-PD) Plan, beginning January 1, 2021.5 Recently, Centers for Medicare & Medicaid Services (CMS) announced that they will delay enforcement until January 1, 2022.6 Despite the delay in enforcement, many states are continuing to pass their own EPCS-required mandates to help address the opioid crisis. Twelve states have already required the use of EPCS prior to December 31, 2020 and an additional 15 states will begin requiring EPCS this year.7

How Your Facility Can Make an Impact in Your Community

MEDHOST EPCS solution is DEA-compliant, Surescripts-certified, and is available in both MEDHOST Emergency Department Information System (EDIS) and MEDHOST Enterprise Electronic Health Records (EHR). To learn more about how MEDHOST can help your facility reduce opioid prescription fraud, improve patient safety, enhance physician workflow, and meet EPCS state and federal requirements, please reach out to us at inquiries@medhost.com or call 1.800.383.6278.

References:

1Preuss, C.V., Kalava, A., & King, K.C. (2020). Prescription of Controlled Substances: Benefits and Risks. StatPearls [Internet]. Retrieved from here.

2Centers for Disease Control and Prevention (CDC).  (2020, March 19). Opioid Overdose. Retrieved from https://www.cdc.gov/drugoverdose/index.html

3The Office of the National Coordinator for Health Information Technology (ONC). (2019, December 18). Health IT Playbook: Opioid Epidemic & Health IT. Retrieved from https://www.healthit.gov/playbook/opioid-epidemic-and-health-it/

4Surescripts. (2020, December). Electronic Prescribing for Controlled Substances. Retrieved from https://surescripts.com/

5Center for Medicare & Medicaid Services. (2020). Medicare Program: Electronic Prescribing of Controlled Substances; Request for Information (RFI). Federal Register 85:150 p. 47151-47157. Codified at 42 CFR §423. Retrieved from https://www.govinfo.gov/content/pkg/FR-2020-08-04/pdf/2020-16897.pdf  

6Center for Medicare & Medicaid Services. (2020). Medicare Program; CY 2021 Payment Policies Under the Physician Fee Scheduled and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Quality Payment Program; Coverage of Opioid Use Disorder Services Furnished by Opioid Treatment Programs; Medicare Enrollment of Opioid Treatment Programs; Electronic Prescribing for Controlled Substances for a Covered Part D Drug; Payment for Office/ Outpatient Evaluation and Management Services; Hospital IQR Program; Establish New Code Categories; Medicare Diabetes Prevention Program (MDPP) Expanded Model Emergency Policy; Coding and Payment for Virtual Check-in Services Interim Final Rule Policy; Coding and Payment for Personal Protective Equipment (PPE) Interim Final Rule Policy; Regulatory Revisions in Response to the Public Health Emergency (PHE) for COVID–19; and Finalization of Certain Provisions from the March 31st, May 8th and September 2nd Interim Final Rules in Response to the PHE for COVID–19. Federal Register 85:248 p. 84472-85377. Codified at 42 CFR §400, 410, 414, 415, 423, 424, and 425. Retrieved from https://www.govinfo.gov/content/pkg/FR-2020-12-28/pdf/2020-26815.pdf

7Imprivata. (n.d). Federal and State Regulations. Retrieved from https://www.imprivata.com/federal-and-state-regulations. Accessed January 3, 2021.