The CMS’ proposed rule requires Part D sponsors to integrate a real-time benefit tool (RTBT) within an electronic medical record (EMRs).
This proposed rule overlooks the option of offering enhanced Formulary and Benefit (F&B) as a solution for prescriber access to more complete drug benefit information.
While we support providing more complete drug and benefit information to prescribers, we believe that RTBT does not offer optimal information during the prescription decision process and should not be required for every ePrescription written. Here are our key observations of RTBT’s place in e-prescribing:
Prescribers need access to better information when selecting a medication. Enhanced Formulary and Benefit data can provide actionable information so that prescribers can make the best choice the first time. The benefits of Enhanced F&B include:
Uses the same source as RTBT
Can be configured to offer prescribers copay information and plan coverage while they are selecting a drug to prescribe
EMRs are already equipped to display F&B data today if the data is available
Offers clarity on preferred drugs and therapeutic alternatives
RTBT has challenges that need to be addressed before it is ready for mainstream use and Formulary & Benefit data is actionable now. A few of the challenges include:
No approved industry standard for RTBT
Many EMRs have not implemented RTBT
Provides information too late within EMR workflow
Many prescriptions will need to be rewritten after real-time data indicates a change is needed
If used for every prescription, increases physician time away from the patient during patient visits
A Comparison Between F&B and RTBT Capabilities
Here is an overview of the capabilities of Enhanced F&B and RTBT.
As this chart indicates, Enhanced F&B is a solution that leverages existing technology infrastructure to provide prescribers with actionable information today.
Our Suggestions to CMS
We believe CMS should encourage more comprehensive and enhanced F&B files and leverage RTBT as a supplement to F&B for affirmation and complex,higher cost medications. With these two solutions, prescribers will be better equipped to select the best drugs for their patients.