In just four months from now, starting in January 2021, CMS will require electronically prescribing controlled substances (EPCS) for Medicare Part D prescribers.

The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act, HR6 - Public Law 115-271, was signed into law on October 24th, 2018. The Act’s primary purpose is to combat the growing opioid epidemic by:

• Teaching addiction medicine by increasing and strengthening the workforce
• Standardizing the delivery of addiction medicine and care
• Covering addiction medicine in a way that facilities the delivery of treatment

One of the more than 60 policies included is the Every Prescription Conveyed Securely Act. This Act will require prescribers to electronically prescribe controlled substances for Schedule II-V drugs covered under a Medicare Part D or Medicare Advantage prescription drug plan. While many states have enacted their own laws requiring e-Prescribing, this is the first federal mandate for EPCS.

According to Surescripts, 55.2% of prescribers in the US are currently enabled for EPCS.  This number is up drastically from only 32% in 2018 when the SUPPORT Act was signed.  The increase is likely due to state-level mandates, as well as the rise of telemedicine usage during the Covid-19 pandemic.

Additional relevant requirements set in place by the SUPPORT Act and CMS rulings that begin in 2021 include:

• Electronic prior authorizations will be required for all Medicare Part D covered drugs requiring a prior authorization. Electronic prescription programs will be required to securely transmit the requests and Part D sponsors and processors must respond electronically using a defined standard. A facsimile, proprietary payer portal, or an electronic form that does not meet the standards will not be counted as an electronic submission.
• Provisions to enhance states’ Prescription Drug Monitoring Programs (PDMPs). The goal is to ensure each state has a PDMP, improve their functionality, make sure all prescribers are utilizing the systems, and foster data sharing between states. Beginning October 1, 2021 states must require health care providers to check their PDMP for a Medicaid enrollee's prescription drug history before prescribing controlled substances to the enrollee.
• On May 23, 2019, CMS published a final rule (CMS-4180-F) requiring that Part D plans adopt one or more real time benefit tools (RTBTs) capable of giving prescribers clinically appropriate patient-specific real-time formulary and benefit information. This mandate is also effective January 1, 2021.

CMS is currently seeking public comments regarding the EPCS requirement. CMS is requesting input as to whether there should be exceptions provided and if so, what circumstances would qualify prescribers for an EPCS exception. CMS also wants feedback on whether penalties should be imposed for noncompliance with the EPCS mandate and if so, what the penalties should be. Comments can be made until October 5^th, 2020.  These rules and exceptions are expected to be provided before the 2021 deadline.

MDToolbox applauds this bipartisan legislation. We are continually encouraging providers to take advantage of the technologies we provide including Electronic Prescribing of Controlled Substances (EPCS), Electronic Prior Authorization (e-PA) and Real-time Price Transparency as they are important tools to use in fighting the devastating opioid epidemic and making electronic prescribing as convenient as possible for prescribers. Putting these federal mandates in place is an important step towards fully utilizing the available technology to save lives. 

This week President Trump signed into law the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act¹. The legislation is aimed at combating the opioid epidemic by focusing on several information technology tools that help prevent prescription fraud and abuse.

One of those tools is e-Prescribing. One of the more than 60 policies included is the Every Prescription Conveyed Securely Act. Beginning in January 2021, prescribers will be required to electronically prescribe controlled substances for Schedule II-V drugs covered under a Medicare Part D or Medicare Advantage prescription drug plan. While many states have enacted their own laws requiring e-Prescribing, this is the first federal mandate.

Another tool included in the law is electronic prior authorization. Also by January 2021, electronic prior authorization will be required for Medicare Part D covered drugs. Electronic prescription programs will be required to securely transmit the requests. A facsimile, proprietary payer portal, or an electronic form that does not meet the standards will not be counted as an electronic submission.

The legislation also contains provisions to enhance states’ Prescription Drug Monitoring Programs (PDMPs). The goal is to ensure each state has a PDMP, improve their functionality, make sure all prescribers are utilizing the systems, and foster data sharing between states. Beginning October 1, 2021 States must require health care providers to check their PDMP for a Medicaid enrollee's prescription drug history before prescribing controlled substances to the enrollee.

MDToolbox applauds this bipartisan legislation. We are continually encouraging providers to take advantage of the technologies we provide including Electronic Prescribing of Controlled Substances (EPCS) and Electronic Prior Authorization (e-PA) as they are important tools to use in fighting the devastating opioid epidemic. Putting these federal mandates in place is an important step towards fully utilizing the available technology to save lives. 

1. H.R.6 - SUPPORT for Patients and Communities Act https://www.congress.gov/bill/115th-congress/house-bill/6

Prior authorizations are one of the biggest frustrations for doctors and their staff. In order to get certain medications approved by patients’ insurance companies, the standard method of paper prior authorizations involves filling out long forms, spending time on the phone, and faxing back and forth potentially multiple times over several days. However, there is now a new alternative. Introducing: Electronic Prior Authorization or e-PA.

What is e-PA?

Electronic Prior Authorization also known as, e-PA, is a streamlined method of completing prior authorizations electronically. A message with the patient’s information and prescription information is securely sent online to the Pharmacy Benefit Managers (PBMs) for review. A lot of the time e-PAs are completed directly in the Electronic Health Record system making it that much easier for the provider and staff to complete in their workflow.

How does e-PA work?

There are several different kinds of electronic prior authorization on the market today.  Many early versions turn the paper forms into PDF documents and give providers a way to fill out those forms online or electronically. Many times they are the same forms as the paper versions but allow online entry and submitting to the insurance company which saves time over manually filling and faxing. Newer e-PA implementations (like MDToolbox offers) take it to the next level by pre-filling all of the patient and medication pertinent information. They also have simple question sets that are filled out and submitted to get the prior approval instead of needing to complete the long forms.

What are the benefits?

• Saves Time for Physicians

In a 2010 AMA survey it was found that physicians alone, not including other staff, spend on average 20 hours a week dealing with prior authorizations¹.  The time saved by using e-PA means that physicians can devote more time to caring for their patients.

•  Saves Time for Patients

The same survey showed 69% of physicians typically wait several days to receive prior authorization from an insurer for drugs, while 10% wait more than one week. By using e-PA, physicians can sometimes get a response immediately, therefore patients would not be stuck waiting several days or making failed attempts to pick up their prescription at the pharmacy.

• Improves Patient Care and Outcomes

20-30% of patients waiting on PAs ultimately give up without getting their prescription² while up to 70% of patients don’t receive the original prescription prescribed by their provider if a prior authorization is required³. Not only will physicians have more time to devote to patient care by reducing the time spent on prior authorizations with e-PA, patients will also be more likely to follow through with their originally prescribed treatment.

• Saves Money

A study presented in Health Affairs put the monetary cost of physicians interacting with insurance plans at $83,000 annually⁴. By utilizing e-PA and reducing administrative efforts put into manual prior authorizations, these costs can be drastically reduced as well.

It is clear to see that there are many obvious reasons providers should be happy to switch to completing prior authorizations electronically and it’s expected that this technology will be a welcome change in offices across the nation.

1. American Medical Association, “New AMA Survey Finds Insurer Preauthorization Policies Impact Patient Care,” November 22, 2010
2. Journal of Managed Care Pharmacy, K.A. Hanson, et.al An analysis of Antihypertensive Use Following Initially Rejected Pharmacy Claims for Aliskiren, Sept. 2009, Vol. 15, No. 7, pg 573-57
3. FrostSullivan Study, The Impact of the Prior Authorization Process on Branded Medications
4. Health Affairs: “What Does It Cost Physician Practices To Interact With Health Insurance Plans?”; May 2009