PSJ and JAPPO on E-Prescribing

THE PHARMACEUTICAL SOCIETY OF JAMAICA (PSJ)

and

THE JAMAICA ASSOCIATION OF PRIVATE PHARMACY OWNERS (JAPPO)

E-PRESCRIBING JOINT STATEMENT

____________________________________________________

Position on E-prescribing

The Pharmaceutical Society of Jamaica and the Jamaica Association of Private Pharmacy Owners agrees, accepts and supports that e-prescribing, along with other health technology solutions have significant benefits and will aid in the delivery of better value to our patients. 

Definition

E-Prescribing is the secure electronic creation and transmission of a prescription between an authorized prescriber and a patient’s pharmacy of choice, using clinical medical software and pharmacy dispensing software. E-prescribing is different from written paper prescriptions that are transmitted via fax, email, or other electronic means such as WhatsApp. Current policy requires that prescriptions transmitted by these means should be presented at the pharmacy in exchange for the medicines. With E-prescriptions, the entire process of generating, signing, transmission and dispensing of the prescription is electronic.

Background and Considerations

We recognize the ongoing efforts of the software providers who have made submissions and waited for many years to establish the software infrastructure to enable e-prescribing.  We also applaud the efforts of the Pharmacy Council of Jamaica and the significant work done by that entity to make recommendations and establish a multi-stakeholder steering Committee for the implementation of e-prescribing in Jamaica.  E-prescriptions reduce the incidence of medication and dispensing errors caused by illegible prescriptions and provides the timely transmission of prescription information from practitioner to pharmacist. It is our joint position that e-prescribing will improve patient care and safety. However, we ask that the Ministry of Health ensure that electronically generated and transmitted prescriptions achieve the same objectives as written prescription. We urge the Ministry of Health to maintain e-prescribing as a priority and take additional measures to accelerate the required guidelines based on the following key considerations:

• Patient confidentiality and security must be maintained

• Patient’s right of choice must be protected

•  The authenticity and accuracy of the prescription must be verifiable

• The process must prevent prescription forgeries and diversion

• Work processes must be streamlined

• e-Prescribing systems ought to be able to integrate with dispensing various software

Based on the above considerations we are making a public appeal to the Ministry of Health to institute policy guidelines to:

·         Ensure that only registered prescribers and pharmacists have access to e-prescribing/e-dispensing systems

·         Prevent prescription fraud and diversion

·         Ensure that electronic signature of prescribers conform to the requirements of the Electronics Transaction Act

·         Define in policy or law whether a printed or an electronic form will be accepted as the auditable original prescription 

·         Set up a Data Protection office with technical staff who is familiar with the Data Protection Act (2020) to assess, approve, and monitor the current e-prescribing systems before the Minister for compliance an adapted ISO standard for data security and the fundamentals of the Data Protection Act.  This office would be single authority for software providers who are processing personal and sensitive health data. The office would also publish guidelines for data sharing among health professionals and for any other use or disclosure of that data

·         Core data elements must conform to the legal requirements of a prescription as in the Pharmacy Regulations section 20(2) and Messaging standards: Health level 7 international

·         Integration between the e-prescribing and e-dispensing software to avoid work process flow challenges

·         Prevent kickbacks based on use of the softwares

·         Ensure access to all software by all pharmacies

·         Ensure patients have the option of printed or e-prescription at the doctor’s office

·         Update the relevant medical and pharmacy legislation and regulations to support e-prescribing