On May 1, 2021, the National Drug List (NLL) Act entered into force. In short, the law means that information about a patient’s prescription and the medicines they collected are collected in a registry, the so-called National Drug List. The registry contains prescriptions for dosing and regular electronic prescriptions, but does not contain medications that are required, and drugs that are directly served in healthcare. The record also includes the aids described on the aid cards and the foods described in the nutritional instructions. The biggest change compared to before is that the patient now has the right to share information about carefully prescribed and combined medications and not just with the pharmacy.
Initially, the NLL is only available via the E-Health Authority web service “Förskrivningskollen”. By May 1, 2023, the list should also be available through journal systems. The E-Health Authority has been mandated by the government to build it, but many actors are involved, like all regions, SKR and Inera.
Implementation of an NLL requires a major healthcare change effort. Prescribing modules and other systems that handle information about prescribed drugs must be rebuilt when the list is made available in medical record systems. It also requires a new, shared way of working and a realistic timetable. You have to listen and learn from the doctors who prescribe medicines for patients. Unfortunately, I and many of the people involved in this process believe that many question marks remain.
I lack a holistic view and understanding of the complexity of prescribing, prescribing, and following up on medications. Members of the Swedish Medical Association who have been involved in working with NLL face substandard dialogue with and a lack of coordination of the work of various public and commercial actors. These shortcomings have caused delays, technical problems, and therefore risks to patient safety.
There are many questions but few answers: What do we do with patients who have no IT skills at all and who no longer receive a prescription? How is it ensured that patients and staff understand the rules regarding prohibition, consent and confidentiality and what does this mean in practice? Is there an organized way to think about how patients can avoid falling between chairs when they don’t have paper prescriptions or annual return visits? Is there an ethical and legal issue in moving prohibited data on drugs in an NLL to the list of prescriptions/drugs in a health care provider’s health care information system?
There are also a lot of practical conflicts between different laws and regulations that have not been sufficiently investigated, both during the preparations for the NLL Act and after its entry into force. One example is the legal provisions relating to the rules for the prohibition and processing of personal data in the NLL Act in relation to the general rules for the processing of personal data in the health care system. For the prescriber, it is important to know what can be done. The EHA has different schedules for when to operate different functions and when to provide specifications to suppliers who have to adapt care information systems for direct access to an NLL. But these tables are not clear, and it seems that some of them have not yet been determined.
This is a small part of the question marks that need to be straightened out. The EHA intends to close the switch on May 1, 2023 and justifies this by the fact that the NLL Act requires that care information systems be fully integrated with the NLL by this date. Is the schedule realistic? No, the Swedish Medical Association and many other stakeholders do not think so. Our proposal instead is that the adapter can remain even after May 1, 2023 and that integration of care information systems against NLL can take place gradually, with read access as the only requirement on May 1, 2023. The Swedish Medical Association will continue to work actively towards making NLL effective – For both patients and doctors.
Läkartidningen 15-16 / 2022