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December 1, 2005

National Committee on Vital and Health Statistics
Subcommittee on Standards and Security
Jeff Blair, Chair
Medical Records Institute
8701 New Hampton Road, N.E.
Albuquerque, New Mexico 87111

Maria Friedman, D.B.A.
Centers for Medicare & Medicaid Services
Office of E-Health Standards & Security
Mail Stop S2-26-17
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: 42 CFR Part 423 Medicare Program; E-Prescribing and the Prescription Drug Program; Final Rule

Dear NCVHS and Maria;

The 42 CFR Part 423 Medicare Program; E-Prescribing and the Prescription Drug Program; Final Rule names NCPDP SCRIPT Standard Version 5.Ø as the foundation standard version of SCRIPT. The industry is already moving to SCRIPT Version 8.1. SCRIPT version 8.1 has been fully balloted and supports all the functionality of 5.Ø while supporting additional functionality, including medication history.

It is the consensus of the NCPDP membership that CMS must name SCRIPT Version 8.1 for eprescribing under MMA instead of Version 5.Ø and specify functions that are required in the foundation standard  (for example, excluding medication history until it has been fully tested). By adopting the NCPDP recommendation, trading partners can move forward with higher versions so long as they:

a) Still support the foundation standard functions, and

b) Are still able to accept any message based upon the foundation standard from a trading partner that has not moved beyond the foundation standard.

In addition, the NCPDP recommendation will allow the industry to make progress in testing new functionality while still supporting minimum standards for eprescribing.

NCPDP stands ready to assist CMS in bringing together industry stakeholders involved in the current prescription processing for the smooth inclusion of the Medicare Prescription Drug Benefit program.



Lee Ann C. Stember
National Council for Prescription Drug Programs (NCPDP)
9240 E. Raintree Drive
Scottsdale, AZ 85260
(480) 477-1000 x 108

cc:  NCPDP Board of Trustees