Attachment N - Public Comment NACDS

VIA EMAIL: OIRA_submission@omb.eop.gov; ATTN: AHRQ’s Desk Officer
October 1, 2009
Carolyn M. Clancy, M.D.
Director, Agency for Healthcare Research and Quality
540 Gaither Road
Rockville, MD 20850
ATTN: AHRQ’s Desk Officer
Dear Dr. Clancy:
The National Association of Chain Drug Stores (NACDS) thanks you for the opportunity to
comment on the proposed information collection project: “Health IT Community Tracking Study
2009.” NACDS represents traditional drug stores, supermarkets, and mass merchants with
pharmacies. Its more than 170 chain member companies include regional chains with a minimum
of four stores to national companies. NACDS members also include more than 1,000 suppliers of
pharmacy and front-end products, and nearly 90 international members representing 29 countries.
Chains operate more than 39,000 pharmacies, and employ a total of more than 2.5 million
employees, including 118,000 pharmacists. They fill more than 2.5 billion prescriptions yearly,
and have annual sales of over $750 billion. For more information about NACDS, visit
www.NACDS.org.
We appreciate that AHRQ seeks to conduct research about how e-prescribing is being
implemented and used by physicians and pharmacies to help provide a more complete picture of
e-prescribing implementation. As AHRQ recognizes, physician adoption of e-prescribing has
been the focus of most policy efforts. It would be helpful to further foster the adoption of this
technology, as AHRQ recognizes, by identifying and shaping strategies that would promote more
effective implementation of e-prescribing in retail pharmacies.
We applaud you for this proposal, and urge you to consider our recommendations as you move
forward. It is clearly stated in the supporting statements for this proposed study that it will be a
qualitative research study of a small number of e-prescribing stakeholders that have been
purposively chosen for participation, and “therefore study findings cannot be statistically
generalized to the respondent universe.” We appreciate the fact that AHRQ has acknowledged
this limitation. However, we are concerned that when the results of this proposed study are
published, there will be insufficient recognition and acknowledgement of the limitations of the
study, and thus there will be considerable misunderstanding within the HIT industry with respect
to the limitations and applicability of the results. We strongly encourage AHRQ to ensure that
the qualitative nature of this study is emphasized both in any research reports that might issue
from the study as well as any and all publicity documents and public interviews of researchers
that might follow.
With respect to interview protocols, we believe that interviewing the “Pharmacist-In-Charge”
would not provide the most helpful information in response to the questions you plan to ask. For
chain pharmacies, we recommend that you interview a person at the corporate headquarters who
has oversight and responsibility for electronic prescribing operations. This would provide you

Agency for Healthcare Research and Quality
October 1, 2009
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with a more informed response with respect to questions concerning policies and strategies.
NACDS would be pleased to serve as a liaison to help identify the proper individuals within our
membership to be interviewed.
On a similar note, to ensure the validity of results obtained from state pharmacy association
representatives in this survey, we ask you to endeavor to survey state pharmacy association
representatives that have direct knowledge of e-prescribing gained through extensive, hands-on
experience using e-prescribing applications, or state pharmacy association representatives that
have extensive knowledge of e-prescribing that has been gained through a systematic collection
and analysis of data from a representative sample of their member pharmacists who are users of
e-prescribing.
Many of the functionalities that AHRQ proposes to include in the interview protocols have not
yet been implemented by pharmacies. Including these functionalities in the interview would be
confusing and/or misleading to the interviewee and of questionable value to the study. The
specific questions to which we refer are listed below. We recommend these questions be deleted:
• Q.AEX.H.04. Do you typically send other types of electronic messages besides renewal
authorization requests to practices with e-prescribing (e.g. delivery confirmation, change
requests)?
•

Q.AEX.H.04.a. If yes: How does pharmacy staff use this feature?

•

Q.AEX.H.04.b. If yes: How frequently is this feature used?

We ask that you delete the following question because it is a general pharmacy regulatory issue
and not directly pertinent to electronic prescribing. Thus, it is not relevant to the purposes of the
survey:
Q.AEX.H.05. If a prescription is written for a brand-name medication when therapeuticallyequivalent generic medications are available and “Dispense As Written” is not indicated, does the
pharmacy typically make a generic substitution or consult the prescribing physician about the
possibility of a substitution?
We thank you again for proposing this information collection, and for the opportunity to provide
our perspectives on its design. Please do not hesitate to contact me if we can provide further
assistance. I can be reached at knicholson@nacds.org or 703-837-4183.
Sincerely,

Kevin N. Nicholson, R.Ph., J.D.
Vice President, Pharmacy Advisor
Government Affairs and Public Policy