Noel Corser

Main comment is that the following section has multiple logical inconsistencies (as well as formatting inconsistencies, suggest a, b rather than 1, 2): "2. A regulated member who transmits (e.g., faxes) a prescription must ensure the: 1. method is secure[G] to protect patient confidentiality and prevent diversion; and 2. provision for the purpose of dispensing can only be received by the intended licensed pharmacy." where "secure" is defined as "Secure: for the purpose of this standard, “secure” refers to the system in which a prescription is transmitted. Secure transmission involves messaging in a closed electronic system (e.g., PrescribeIT).1" and "provision" is defined as "Provision: the format in which a prescription is provided to a patient or transmitted to a pharmacy. This includes: • produced by computer and hand-signed by the prescriber or affixed with an electronic signature that is initialled by the prescriber, then provided to the patient or faxed directly to the pharmacy from the prescriber; • faxed directly from a password-protected electronic medical record (EMR) where the prescriber’s password protocol is the prescriber’s direct authorization in the absence of a signature; • issued and transmitted via secure messaging in a closed electronic system (e.g., PrescribeIT) that enables monitoring and shared access by authorized prescribers and dispensers; or • provided to the pharmacy verbally by telephone by the prescriber or their authorized intermediary.1 Note: handwritten prescriptions are acceptable; however, there is a degree of risk for forgery or diversion. Alternate means of providing the prescription directly to the pharmacy of the patient’s choice is preferable." For extra clarity, paragraph 2 is about "transmitting (e.g., faxing)" a Rx, but subsection (2) is included to cover Rxs given to the pt by hand; "secure" in the context of "transmitting (e.g. faxing)" means something beyond faxing, e.g. PrescribeIT; etc. Point of being nit-picky is that paragraph (2) ties this important issue up in knots, and needs sorting out. Clearly, if a Rx is given directly to a patient, it's impossible for the doc to also ensure the Rx "can only be received by the intended licensed pharmacy". Perhaps different requirements for hand-written Rxs given directly to patients, compared to faxing, compared to electronic options, makes more sense? These really are apples, oranges, and bananas.

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