Indiana Mandates Electronic Prescribing

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Indiana Governor Eric Holcomb recently signed SB176 into law. This Act mandates Indiana healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  This bill began as an 8-line document allowing patients to transfer their prescription to another pharmacy.  Several amendments were made in the two weeks it took the Indiana House and Senate to pass the bill bringing it to 15 pages in length.

Other subsections include:

  • The Act amends several sections of state code by adding the phrase “or electronically transmit” to add electronic prescribing as a valid means of prescribing.
  • There are provisions in the Act for a waiver system with similar circumstances for approval as other states have enacted.  Some of these include: economic hardship, technological limitations, and other circumstances determined by the board.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.
  • The Act allows for advanced practice registered nurses to send prescriptions under their own credentials once they have met the requirements established by the board, previously nurse practitioners were required to send prescriptions under a supervising physicians’ credentials.
  • Telemedicine is also addressed in this Act.  Indiana has allowed for the prescribing of controlled and non-controlled (excluding opioids) prescriptions for telemedicine providers so long as certain criteria is met.  One regulation is that an Indiana licensed practitioner has seen the patient in person and developed a medical plan that the telemedicine prescriber is following. (Note: Stay tuned for our next blog concerning U.S. Wide Telemedicine Prescribing that goes into more details about the uncertainty of telemedicine and the current laws governing it.)

Indiana has remained below the national average for opioid-related overdose deaths since 1999, following the national trend and increasing in number of deaths.  However, the rate has increased sharply in recent years catching up with the national average.  If the rate continues as forecasted, it will pass the national average for the first time since the National Institute on Drug Abuse has been collecting data.  Prescription opioid overdose deaths decreased in 2011 but have begun to rise again in recent years along with heroin and synthetic opioid deaths.  Indiana enacted SB226 on April 26th, 2017, the Act limits the first fill prescription of opioids to seven days for adults.  The law also limits opioid prescriptions for minors to seven days.  Prescriptions can exceed seven days under certain circumstances, such as the doctor determines that the patient requires it and if the patient is in palliative care.[1]

Indiana currently has a 30.5% provider enablement for electronic prescribing of controlled substances, which is just below the national average of 33.4%.  Pharmacy enablement for EPCS is 97.8% which is above the current nation average for pharmacies, which is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Indiana now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Indiana to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

[1]http://www.hallrender.com/2017/06/21/new-indiana-law-imposes-a-seven-day-limit-on-opioid-prescriptions/

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances

Tennessee Amends and Delays E-Prescribing Mandate

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Tennessee Governor Bill Haslam recently signed SB0810 into law.  This Act mandates Tennessee healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  Tennessee had previously passed HB1993 which mandated EPCS for Schedule II drugs by January 1st, 2020.  This latest Act makes several changes to the prior legislation:

  • The new Act replaces Schedule II drugs with Schedule II-V.  Now, all controlled substances are required to be electronically prescribed. 
  • The required date for prescribers to follow the mandate has been postponed to January 1st, 2021 from January 1st, 2020. 
  • Tennessee pharmacies are now required to be able to issue partial prescriptions in their electronic system of Schedule II drugs by January 1st, 2020 or face action by The Board of Pharmacy.  Tennessee previously passed 63-1-163 which regulated pharmacies when filling partial prescription orders.  The new amendment requires the pharmacy’s electronic system to be able to split the medication orders should a patient only want a partial order, or if the pharmacy is low on stock of the Schedule II drug.

Tennessee has remained above the national average for opioid-related overdose deaths since 2003, rising even faster than the national trend in number of deaths.  While some states have had a flattening or reduction in prescription opioid overdose deaths in recent years, Tennessee has continued to trend upward.  The number of deaths from synthetic opioids and heroin had remained stable until 2014, when the numbers began to rise.

Last year, Tennessee passed HB1831: “TN Together Opioid Reform” which made several major strides toward the fight against opioid addiction.  The Act budgeted $30 million for prevention, treatment, and law enforcement tasks in relation to the opioid epidemic.  The Act also mandated that pharmacies check the State PMP registry.  The biggest change has to do with how much of a drug you can get and when. Under the new law, pharmacists can only partially fill a prescription for no more than half of the number of days it’s written for. And there are limits on prescriptions, too: General prescriptions are limited to a 10-day supply (and no more than 500 cumulative morphine milligram equivalents).[1]

Tennessee currently has a 23.5% provider enablement for electronic prescribing of controlled substances, which is well below the national average of 33.4%.  Pharmacy enablement for EPCS is 96.7% which is above the current nation average for pharmacies is 95.2%.[2]  HB1993, which was passed a year ago would have required EPCS of Schedule II drugs only 8 month from the writing of this blog.  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Tennessee now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Tennessee to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://www.knoxnews.com/story/news/health/2018/06/29/tennessee-opioid-prescription-law-pharmacy/746208002/

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Colorado Mandates Electronic Prescribing

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Colorado Governor Jared Polis recently signed SB079 into law. This Act mandates Colorado healthcare providers to electronically prescribe controlled substances that are scheduled as II-IV with an effective date of either July 1st, 2021, or July 1st 2023.  The Act breaks down the medical field to several categories of healthcare providers: podiatrists, dentists, optometrists, advanced practice nurses, physicians, and physician assistants.  For each practitioner category there is a provision for those who are practicing in a rural area of the state or are a sole-practitioner to postpone the mandate from July 1st 2021 to July 1st 2023.  Dentists are mandated for EPCS by July 1, 2023 regardless of if they serve a rural or urban community.

Other subsections of this Act include:

  • The act contains provisions for a waiver to using EPCS as many State Mandate laws do, however Colorado allows for practitioners who write less than 25 prescriptions for controlled substances per year to not have to adopt electronic prescribing.
  • Prescribers are required to indicate on their license renewal whether they have complied with the EPCS mandate.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.

Colorado has remained slightly above the national average for opioid-related overdose deaths since 1999, following the national trend and increasing in number of deaths.  The rate then flattened in 2015 and 2016, falling below the national trend.  Heroin related deaths have been climbing; however, prescription opioid deaths have been slightly declining in recent years.

Several legislative initiatives have been enacted as Colorado continues the fight against the opioid epidemic.  In 2017, the general assembly enacted Senate Bill 17-074, which created a 2-year medication-assisted treatment (MAT) expansion pilot program, administered by the university of Colorado college of nursing, to expand access to medication-assisted treatment to opioid-dependent patients in Pueblo and Routt counties. The 2017 Act directs the general assembly to appropriate $500,000 per year for the 2017-18 and 2018-19 fiscal years from the marijuana tax cash fund to the university of Colorado board of regents, for allocation to the college of nursing to implement the pilot program. The pilot program repeals on June 30, 2020.[1]  Currently, Senate Bill 19-001 is under consideration to expand and continue the MAT in future years.  Colorado also passed Senate Bill 18-022 in 2018, which limits the quantity of opioids that a patient can receive.

Colorado currently has a 31.7% provider enablement for electronic prescribing of controlled substances, which is just below the national average of 33.4%.  Pharmacy enablement for EPCS is 97.4% which is above the current nation average for pharmacies, which is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Colorado now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Colorado to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://leg.colorado.gov/bills/sb19-001

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Kentucky Mandates Electronic Prescribing

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Kentucky Governor Matt Bevin recently signed HB342 into law. This Act mandates Kentucky healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021

Other subsections of this Act include:

  • The act contains provisions for a waiver to delay the mandate for a specified time period for e-prescribing in the event of economic hardship, technological limitations, or exceptional circumstances, these are to be determined.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.

Kentucky has remained above the national average for opioid-related overdose deaths since 2001, several years were double the national rate.  In 2000, only nine counties in the U.S. had overdose death rates of more than 20 per 100,000 people, and four of these were located in Kentucky.  By 2014, more than half of Kentucky counties had overdose rates that high.  This represents a quadrupling of deaths due to drug overdose, from less than 250 in 2000 to more than 1,000 each year since 2010.  According to the Kentucky Justice and Public Safety Cabinet, drug overdose deaths reached 1,248 in 2015. [1]

Over the past two decades, the Commonwealth has taken efforts to curb problems related to substance use. In 1998, Kentucky became one of the first states to launch a prescription drug monitoring program—the Kentucky All Schedule Prescription Electronic Reporting (KASPER) system to monitor medical use of controlled substances, such as prescription opioid painkillers. KASPER has since been enhanced and now offers health care providers and pharmacies real-time 24-hour access to prescription information that can be used to monitor and prevent overuse of prescription medications.  Policymakers have also adopted policies aimed at reducing the impact of illegal drugs, such as passing the 2015 Senate Bill 192, which authorized expanded use of naloxone, a drug that treats opioid overdoses, and funded substance use treatment programs.[2]

Kentucky currently has only 18.9% provider enablement for electronic prescribing of controlled substances, which is below the national average of 33.4%.  Pharmacy enablement for EPCS is 98.1% which makes Kentucky one of the states with highest percentage of pharmacies ready to receive electronic prescriptions.  The current nation average for pharmacies is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Kentucky now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Kentucky to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://www.healthy-ky.org/res/images/resources/Full-Substance-Use-Brief-Final_12_16-002-.pdf

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Wyoming Mandates Electronic Prescribing

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Wyoming Governor Mark Gordon recently signed Enrolled Act No 66/SF0047 into law. This Act mandates Wyoming providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  The Act has provisions for the state board to provide some exemptions to the requirement for emergencies and has the power to grant an extension to a dispenser or practitioner; however, being granted an extension is not guaranteed.

Other subsections of this Act include:

  • Prior to writing a prescription for a controlled substance, providers are required to search the state PMP database, as well as every 3 months thereafter for as long as the patient remains on a controlled substance.
  • Pharmacies must submit their dispense data on controlled substances to the state daily.
  • All prescribing providers are required to take 3 hours of continuing education every two years related to the responsible prescribing of controlled substances when they renew their license.
  • All Schedule II prescriptions require either written or electronic prescription until the 1/1/21 mandate, oral orders will not be accepted.
  • All Schedule III and IV prescriptions shall not be refilled more than six months after the prescribed date, and not refilled more than five times unless renewed. 

In recent years, Wyoming has fallen below the national average for opioid-related overdose deaths.  However, prior to 2015 Wyoming was above the national average for 5 consecutive years[1].  The state trends continue to rise along with the national average of opiate-related deaths.  Wyoming currently has only 17.5% provider enablement for electronic prescribing of controlled substances[2], well below the national average.  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Wyoming now aligns with several other states mandating electronic prescribing. MDToolbox looks forward to working with providers throughout Wyoming to ease the transition and help provide tools and resources in combating the opioid epidemic. With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

[1]https://www.drugabuse.gov/drugs-abuse/opioids/opioid-summaries-by-state/wyoming-opioid-summary

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Walmart to Limit Opioid Prescriptions and Require EPCS

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Walmart recently announced they will be implementing two new policies aimed at combating opioid abuse1. They include:

  • Restrict initial acute opioid prescriptions to no more than a seven-day supply, with up to a 50 morphine milligram equivalent maximum per day
  • Require e-prescriptions for controlled substances (EPCS)

The policies will apply to all Walmart and Sam’s Club pharmacies in the United States and Puerto Rico. The 7-day limit policy is set to be enforced within the next 60 days. The EPCS requirement will not go into place until January 1, 2020 but it is an important piece since electronic prescriptions prevent fraud and minimize errors.

While many states have either already implemented or are in the process of implementing laws to limit opioids and require EPCS, this is the first large pharmacy chain we have seen implement such measures. Some states limit opioid prescriptions to fewer than 7 days in which case they will default to the state law.

“We are taking action in the fight against the nation’s opioid epidemic,” said Marybeth Hays, executive vice president of Health & Wellness and Consumables, Walmart U.S. “We are proud to implement these policies and initiatives as we work to create solutions that address this critical issue facing the patients and communities we serve.”

Walmart also plans to give access to the controlled substance tool, Narxcare, to all pharmacists, provide naloxone recommendations for patients at risk of overdose, and have additional trainings and education on opioid stewardship by the end of this summer.

At MDToolbox, we agree that these are all important measures to take in the fight against the opioid epidemic. We continually urge prescribers not to wait for such policies to be enacted and to start e-Prescribing controlled substances as soon as possible. Find out more about EPCS or contact us for a demo to see how easy it is to implement.

1. https://news.walmart.com/2018/05/07/walmart-introduces-additional-measures-to-help-curb-opioid-abuse-and-misuse

Electronic Prescription Directions Vary Greatly in Content and Quality

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Electronic prescriptions allow for providers to enter any free-text directions (Sig) they wish, just as if they were writing a paper prescription. The patient directions are one of the most critical parts of a prescription. It’s a huge safety risk if patients do not understand how to use their prescription or if a pharmacist has to try to interpret what the provider means. In a recent study that analyzed 25,000 electronic prescriptions issued by 22,152 community-based prescribers using 501 e-prescribing software applications, it was found that there was a large number of variations in the electronic prescription directions1. The quality of the directions also varied greatly.

The study was conducted by Yuze Yang, PharmD, from Surescripts and colleagues, and published online in the Journal of Managed Care & Specialty Pharmacy. Out of the 25,000 e-prescriptions, there were 3,797 unique Sigs concepts identified in the Sig text strings. However, more than half of all patient directions could be classified into just 25 unique Sig concepts. There were large numbers of variation of even what would be considered simple and straightforward directions found. For example, over 800 permutations of words and phrases used to convey "take one tablet by mouth once daily" were identified.

The researchers not only looked at the variations, they also analyzed the Sig text strings for quality-related events which were defined as “Sig text content that could impair accurate and unambiguous interpretation by staff at receiving pharmacies.” The biggest quality issue observed was incomplete Sigs. Prescriptions were commonly missing relevant dosages or administration frequency/timing information. They found that more than one in ten prescriptions contained some sort of quality issue.  Considering the number of electronic prescriptions that are sent and the not only time-wasting potential but possibly catastrophic results that could come from such quality issues, that figure is way too high.

The authors' recommendations for reducing the quality issues and variations include:

  • Enhancing e-prescribing application user interfaces and Sig creation tools
  • Improving end-user training and usability testing for optimal use of system functionalities
  • Adopting and implementing the currently available Structured and Codified Sig format by both prescriber and pharmacy systems to facilitate improved standardization and interoperability

At MDToolbox, patient safety and ease of use for prescribers are two of our main focuses when designing our directions input fields. We offer several options designed to make entering quality directions as easy as possible:

  • Sig builder – build complete directions in just a few easy clicks
  • Common Sigs – choose from the most commonly used Sigs already available in the system
  • Saved favorite directions – prescribers can enter directions that they commonly use and save them as a favorite with a shortcut that can be quickly accessed
  • Free-text directions – although free-text directions open it up to possible quality errors, MDToolbox has implemented quality checkers to ensure that free-text directions are not missing any of the information the contributes to many of the quality issues such as “how much” or “how often” the prescription should be used.

MDToolbox is also constantly looking for ways like our quality checkers to enhance these areas even more. Part of the way we do this is by conducting usability tests and end-user trainings in order to get feedback from users and ensure users are taking advantage of the available tools. We share a goal with Surescripts to have zero-error e-prescribing and are continually striving towards this goal.

 

  1. Quality and Variability of Patient Directions in Electronic Prescriptions in the Ambulatory Care Setting https://www.jmcp.org/doi/10.18553/jmcp.2018.17404 

Mandated Nationwide E-Prescribing of Controlled Substances Proposed in Bipartisan Senate Bill

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Earlier this week, a bipartisan group of U.S. Senators introduced the Every Prescription Conveyed Securely (EPCS) Act. Under the act, all controlled substance prescriptions under Medicare would have to be sent electronically. The aim of the bill is to combat the opioid epidemic by preventing fraudulent prescriptions and doctor shopping.

The legislation was introduced by four senators: Elizabeth Warren, D-Massachusetts; Michael Bennet, D-Colorado; Dean Heller, R-Nevada, and Pat Toomey, R-Pennsylvania.

As we wrote about previously, companion legislation was introduced in the House of Representatives in July by Congressman Markwayne Mullin (R-OK) and Congresswoman Katherine Clark (D-MA). House bill 35281 has a lot of bipartisan support with 21 cosponsoring representatives including 11 Republicans and 10 Democrats.

“We need to be using every tool at our disposal to fight the opioid epidemic,” Warren said in a statement2. “I’m glad to partner with Senator Bennet on a bipartisan bill that will help gather better data on the opioid epidemic while also helping health care providers make the best decisions for their patients.”

A Department of Justice report recently released found that misused prescription opioids are often obtained illegally using forged or altered prescriptions and by consulting multiple doctors. It was also found that most prescription fraud remains undetected.

“An epidemic of this magnitude requires us to address all aspects of the problem, starting with how providers prescribe opioids,” Bennet said in the statement. "This bipartisan legislation would expand a critical tool to track the use of opioids, ultimately reducing overdoses and saving lives."

Toomey added to the statement, “This commonsense measure will help improve tracking of opioid prescribing and reduce diversion due to forged prescriptions. This is a simple but important step in the direction of curbing opioid abuse.” Heller further added by stating, “This bipartisan legislation takes a critical step toward eliminating doctor shopping and duplicative or fraudulent prescriptions.”

The bill is proposed to go into effect in 2020 and does allow for some exceptions. These include prescriptions generated and dispensed by the same entity, economic hardship, technological limitations and other exceptional circumstances.

At MDToolbox, we strongly encourage all providers to not wait for legislation and to take advantage of the benefits of e-Prescribing controlled substances as soon as possible. It not only prevents fraud but makes things easier for prescribers as well. We are happy to answer any questions you may have about getting started with EPCS and offer a free 30 day trial so that you can see how quick and easy it is.

 

1.       H.R.3528 - Every Prescription Conveyed Securely Act https://www.congress.gov/bill/115th-congress/house-bill/3528
2.       Warren, Bennet, Heller, Toomey Introduce Bill to Combat Opioid Crisis with E-Prescriptions https://www.warren.senate.gov/newsroom/press-releases/warren-bennet-heller-toomey-introduce-bill-to-combat-opioid-crisis-with-e-prescriptions

Opioid Commission Recommends Increased Electronic Prescribing

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President Donald Trump declared the opioid epidemic a national public health emergency on October 26, 2017. In his address, Trump called opioids the “worst drug crisis in American history.”

After the President’s declaration, the President’s Commission on Combating Drug Addiction and the Opioid Crisis issued its final report1. In the Chairman’s letter written by Governor Chris Christie, he points out that 175 Americans are dying a day from this epidemic. The 131-page report goes on to include more than 50 recommendations.

One of the most prudent recommendations is that the Office of National Drug Control Policy (ONDCP) and the DEA increase electronic prescribing to prevent diversion and forgery. They also recommend that the DEA revise the Interim Final Rule which lays out the requirements for electronically prescribing controlled substances in order to make registration and using EPCS easier.

Other recommendations include mandatory PDMP checks, the creation of a Department of Justice-led data-sharing hub, and integrated PDMP data in EHRs. The report suggests passing the Prescription Drug Monitoring (PDMP) Act of 2017 which mandates using PDMPs in states that receive federal funding. This Act also directs the Department of Justice (DOJ) to fund the establishment and maintenance of a data-sharing hub so information could be shared across states. The Commission points out that many providers resist using PDMPs because they don’t integrate well into EHRs, so they believe improving these integrations is necessary to increase effectiveness.

While these are great strides in the right direction, there is still a huge issue at hand. Trump did not mention any specific actions the administration will take or how they will be funded. With only declaring it a national public health emergency as opposed to a national emergency, there is not much more funding available. The commission’s report urges Congress and the Administration to block grant federal funding for opioid-related and SUD-related activities to the states. However, the report does not address the amount of funding needed for their recommendations.

1. https://www.whitehouse.gov/sites/whitehouse.gov/files/images/Final_Report_Draft_11-1-2017.pdf

Forwarding Unfilled Electronic Prescriptions for Controlled Substances

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The pharmacy protocol for forwarding unfilled e-Prescribed controlled substance prescriptions was recently clarified by the Drug Enforcement Agency (DEA). The DEA has specified that if for any reason one pharmacy cannot fill the original controlled substance e-Prescription, it may be forwarded to another DEA-registered pharmacy. This was clarified by the DEA’s associate section chief of the liaison and policy section of the DEA’s Diversion Control division Loren Miller in an email to National Association of Boards of Pharmacy CEO Carmen Catizone1.

The email states, “As posted in the preambles of the [notice of proposed rulemaking] and the [interim final rule], an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy, and this includes Schedule II controlled substances.”

The National Association of Chain Drug Stores (NACDS) had contacted the DEA for clarification on the issue in May and applauded the response that was received.2 “Simply put, this guidance encourages the use of electronic prescribing for controlled substances, and removes a substantial barrier to doing so,” NACDS president and CEO Steve Anderson, IOM, CAE said. “Electronic prescribing has significant advantages over other forms of transmitting a prescription because it reduces opportunities for fraud and abuse. NACDS is unwavering in its commitment to working with all parties to help find and implement solutions to opioid issues, while providing appropriate patient care. This has been, and remains, a top priority of NACDS, and we appreciate the DEA's action on this guidance, which we consider to be entirely consistent with patient care and with the proper handling of controlled substances.”

This is an important clarification that benefits both patients and prescribers by streamlining the process. It eliminates the need for a pharmacist to call the prescriber for a new prescription if it needs to be sent to a different pharmacy. This makes it quicker for patients to receive the medications they need and makes less work for the prescribers. This helps encourage prescribers to e-Prescribe which in turn improves prescription safety and prevents fraud and abuse.

 

1. http://www.ncbop.org/PDF/LMillerDEAGuidanceTransferofOnFileCSPrescriptions.pdf

2. NACDS Applauds DEA Guidance on Forwarding of Electronic Prescriptions for Controlled Substances  

https://www.nacds.org/news/nacds-applauds-dea-guidance-on-forwarding-of-electronic-prescriptions-for-controlled-substances/