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/

Arkansas Mandates Electronic Prescribing

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Arkansas Governor Asa Hutchinson recently signed Act No 447/SB174 into law. This Act mandates Arkansas healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  Arkansas does not recognize Marijuana as a Schedule I drug.  The state has added a Schedule to their classification; Schedule VI, and classified marijuana as such.  The act refers to all controlled substances as Schedule II-VI.

Other subsections of this Act include:

  • Schedule III and Schedule IV drugs shall not be filled or refilled more than six months after the date of prescribing or be refilled more than five times unless renewed.
  • 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.
  • 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 practitioner licensing board can issue a $250 fine for each violation of failure to e-prescribe a controlled substance.

Arkansas has remained below the national average for opioid-related overdose deaths since 2009.  However, in 2016 Arkansas was one of just eight states to fail the “National Safety Council: Prescription Nation” report that analyzed prescription drug usage state-by-state.   Arkansas was found to be ranked second in the list of highest rate of opioid prescribing states in the US[2].  The state government has worked hard since this ranking to get opioid prescriptions under control by requiring opioid education for practitioners, psychological therapy for patients while they are taking controlled substances, and additional support for inmates.

Arkansas currently has only 24.6% provider enablement for electronic prescribing of controlled substances, which is below the national average of 33.4%[3].  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Arkansas now aligns with several other states mandating electronic prescribing. MDToolbox looks forward to working with providers throughout Arkansas 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/arkansas-opioid-summary

[2]https://www.nwaonline.com/news/2018/nov/11/arkansas-and-the-opioid-epidemic-201811/?opinion

[3]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/

37 States Now Sharing Prescription Data

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Massachusetts, New Hampshire, New York and Texas are the four most recent states to join the prescription monitoring program (PMP) run by the National Association of Boards of Pharmacy (NABP) – NABP PMP InterConnect1. This brings the total number of states connected to 37, making it the largest prescription data sharing network. Over 3.9 million requests and 8.2 million responses are processed through the system each month.

The complete list of connected states includes: Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Nevada, New Jersey, New Hampshire, New Mexico, New York, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, West Virginia and Wisconsin.

It is expected that other states will be joining soon too. “We’re excited about the growth and response to PMP InterConnect,” said NABP President Hal Wand, MBA, RPh. “Our goal is to reach every state with a PMP to guarantee a true connection across our country in an effort for greater medical knowledge and our patients’ safety.”

There is no charge to the states to use the system and it’s setup to enforce each state’s data-access rules. Authorized healthcare professionals including physicians and pharmacists in each of the connected states are able to access multi-state histories of their patients’ controlled substance prescriptions. This is an important tool in combating prescription drug abuse and identifying potential problems by allowing providers to see a comprehensive history, especially for those patients who cross state lines.

1. "Four States Join NABP PMP InterConnect, the Nation’s Largest Prescription Data Sharing Network," National Association of Boards of Pharmacy (NABP) https://nabp.pharmacy/four-states-join-nabp-pmp-interconnect-nations-largest-prescription-data-sharing-network/

2017 Brings Changes to Medicare Incentive Programs and Meaningful Use

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As we ring in the new year, medical providers now can say goodbye to the CMS’s “Meaningful Use Incentive Program” (MU) and start preparing for the new Medicare incentive program.

Providers who used qualified systems in 2016 can still attest to Meaningful Use for the 2016 year (you must have been a “meaningful user” of certified electronic medical record system(s) for the minimum reporting period. Visit this website for more info on how the previous year’s MU programs worked and deadlines for attesting: 

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2016ProgramRequirements.html

Now in 2017, Meaningful Use will become one of four components of the new “Merit-Based Incentive Payment System” or MIPS. MIPS is part of the bigger Medicare Access and CHIP Reauthorization or MACRA.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) ended the Sustainable Growth Rate formula, which threatened clinicians participating in Medicare with potential payment penalties for 13 years.  

The MACRA program introduces two paths that Medicare providers can choose from for participation:

  • Advanced Alternative Payment Models (APMs) (providers apply for a special payment model program) or
  • The Merit-based Incentive Payment System (MIPS)  (a performance-based program)

 

Who Does this Affect?

Providers who are in an Advanced APM or who bill Medicare for more than $30,000 a year and care for more than 100 Medicare patients a year are affected. Providers with less than that are not affected and not part of the program.3  This includes:

  • Physician
  • Physician assistant
  • Nurse practitioner
  • Clinical nurse specialist
  • Certified registered nurse anesthetist

 

Advanced Alternative Payment Models (APMs)

The Advanced APMs program allows certain providers to apply for the APM track. This gives added incentive payments to provide high-quality and cost-efficient care. See the APM website for more information on the special programs and how providers can apply:

https://qpp.cms.gov/learn/apms

 

The Merit-based Incentive Payment System (MIPS)

Most Medicare Providers will be part of MIPS. They will earn a payment adjustment based on evidence-based and practice-specific quality data submitted. According to CMS, the Quality Payment Program policy will reform Medicare payments for more than 600,000 clinicians across the U.S.

Providers participating in the program in 2017 will submit their data by March 2018 and based on submission, their 2019 Medicare payments will be adjusted up, down, or not at all. 

MIPS is broken down into four categories and is setup so that the more Providers participate (and attest to), the higher score (and incentive) providers will get. A Medicare provider who does not participate at all (0%) may see up to 4% negative adjustment in 2019. A provider with a minimal amount of participation (e.g. submit one measure) may be able to avoid adjustment. For partial submission (submit the minimums for a partial year) they will see neutral or positive adjustments, and submit a full year and earn a positive payment adjustment.

CMS has setup a new website for the Quality Program4 which breaks down the four components of the MIPS:

  • Quality (replaces PQRS)   (60%)
  • Improvement Activities (new)  (25%)
  • Advancing Care Information (replaces Meaningful Use)   (15%)
  • Cost (replaces Value Based Modifier)   (0% in 2017)

Image Credit:  MIPS Quality Payment Program Website:  https://qpp.cms.gov/measures/performance

 

If we take a quick look at how each category works:

  •  Quality
    •  Most Providers will report up to 6 quality measures (including an outcome type measure). Quality measures selected should be focused based on type of care and specialty as appropriate.
    •  Reporting period must be a minimum of 90 days.
    • There are over 250 quality measures available, be sure to check your health record software system to see which ones they support (can help gather data for you) when planning.
    • Measures go across many specialties and problem sets:  For example, “Age Appropriate Screen Colonoscopy” – Report the percentage of patients greater than 85 years old seen by the Provider who received a colonoscopy screening Jan 1 to December 31.
  •  Improvement Activities
    • Most Providers will attest to completing a minimum of 4 improvement activities for at least 90 days.
    • As of the writing of this blog, the CMS tools shows 92 activities to choose from.
    • Activities range from care coordination, patient safety changes and beneficiary engagements.
    • Examples: Join and participate (for a minimum of 6 months) in your States Prescription Monitoring Program (PMP). Or another example: Engage patients, family and caregivers in developing a plan of care and prioritizing their goals for action, documented in the certified EHR technology.
  • Advancing Care Information
    • Use a qualified (certified) product (or products) for a minimum of 90 days.
    • There are two different programs to pick from depending on your Electronic Health Record Software Certification. For 2017, you will be able to use either a 2014 Certified Product (previously called Stage 2 MU Certification) or a 2015 certified product (certified for the MU Final Ruling criteria). Attest to a minimum of:
      • E-Prescribing
      • Provide Patient Access
      • Send Summary of Care Records
      • Receive Summary of Care Records
      • Report up to 9 additional measures for bonus credits
  • Cost
    • No actions required: Cost will be computing from your claims
    • The cost category will be calculated in 2017, but will not be used to determine your payment adjustment. In 2018, CMS will start using the cost category to determine your payment adjustment.

 

Medicare Providers will want to research the programs and decide their level of participation early in 2017. Full year participation would require making sure their Electronic Health Record system is setup for minimal data tracking and other required features like E-Prescribing and Direct Messaging.

 

References

  1. 2017 Program requirements:

    https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2017ProgramRequirements.html

  2. MIPS and MACRA:

    http://www.impact-advisors.com/meaningful-use/mips-macra-mu-the-next-evolution-of-healthcare-payment-reform/#sthash.vMkVGSvN.dpuf

  3. https://qpp.cms.gov/docs/Quality_Payment_Program_Overview_Fact_Sheet.pdf

  4. MIPS Quality Payment Program Website: 

    https://qpp.cms.gov/measures/performance

The Evolution of EPCS

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Electronic prescribing of controlled substances (EPCS) is just starting to gain ground.  The Drug Enforcement Agency (DEA) rule allowing prescribers to electronically write prescriptions for controlled substances actually went into effect over three years ago.  However, its adoption has been slow. 

The need to be able to send controlled substances electronically is definitely there.  Approximately 11% of all prescriptions written are for controlled substances and 90% of prescribers write prescriptions for such drugs1.  If these prescriptions can’t be sent electronically, prescribers must handwrite or print them.  This can be a big interruption and slowdown in a prescriber’s workflow.  In addition, EPCS increases safety and decreases fraud.  So why is it taking so long for EPCS to become a norm? 

The DEA’s Interim Final Rule (IFR) first approved electronic sending and receiving of controlled substances in March 2010, and it went into effect on June 1, 2010.  Though in order to actually use EPCS, prescribers, e-Prescribing software, and pharmacy software must meet strict regulations.  Prescribers are required to go through stringent identity proofing and receive two-factor authentication credentials.  Each time they send a controlled substance, prescribers must use their two-factor authentication.  The two-factor has to be two of the following three items:

1) Something only the prescriber KNOWS, like a password or an answer to a challenge question

2) Something the prescriber IS, biometric data such as a fingerprint or 

3) Something the prescriber HAS like a device or token separate from the computer he is prescribing on.   

E-Prescribing software and pharmacy software must go through a DEA Certification or third-party audit to verify they comply with the regulations.  The IFR requires e-Prescribing software to have a two-factor authentication protocol, have access controls so only prescribers with the proper permissions can send controlled substance prescriptions, and put extra security and auditing measures in place.  Pharmacy software is also required to have access controls and stricter security measures, as well as additional features to be able to receive electronic controlled substance prescription orders.

In addition to the Federal DEA requirements, each state has their own laws and regulations concerning EPCS.  While 47 states have approved EPCS, there is still a small percentage of pharmacies in each of these states that are able to receive electronic prescriptions for controlled substances. 

It is clear that meeting all of these requirements can be challenging and takes ample time and money for all involved.  This has caused the progression to be quite slow.  Here’s how it looks on a year-by-year basis:

2010: DEA IFR goes into effect and states begin aligning their rules with those of the DEA.

2011: Software vendors working to meet requirements.

2012: First e-Prescribing and pharmacy software vendors certified.  Surescripts® reports a “modest number of EPCSs” transmitted in eight states as of May 2012.   

2013: About 14,000 pharmacy stores signed up for EPCS in 44 states, but only about 1,000 prescribers nationwide using EPCS as of Mid-2013.

2014: About 20,000 pharmacy stores signed up for EPCS in 47 states.  However, only 14 e-Prescribing systems certified for EPCS out of over 600 prescribing applications on the Surescripts® network. 2

 

Out of almost 70,000 total pharmacies and more than half a million e-Prescribing prescribers, the numbers of those using EPCS are still small.  However, that’s changing as EPCS growth takes off.

As one of the 14 certified Prescriber EPCS systems, MDToolbox is at the forefront of the EPCS movement.  We see now as the time that EPCS is going to take off.  MDToolbox is offering both standalone EPCS for prescribers and EPCS plug-in modules for EHRs looking for a quick and inexpensive way to get on-board with the movement.  With laws like New York’s I-STOP mandating ALL prescriptions be sent by March 27, 2015, we believe EPCS will see huge growth in 2014. 

What do you think?  We would love to hear from you and get your feedback, comments and questions. Leave a comment below or feel free to contact us at info@mdtoolbox.com.     

 

  1. Rannazzisi JT. A Prescription for Waste: Controlled Substance Abuse in Medicaid. Drug Enforcement Administration (DEA). September 30, 2009. www.justice.gov/dea/pr/speeches-testimony/2012-2009/ct093009.pdf. Accessed January 27,2014.
  2. Surescripts - http://www.surescripts.com/medication-network-services/e-prescribing-of-controlled-substances/regulatory-status-map

e-Prescribing Software: Top 5 Benefits for EHRs/EMRs

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Keeping in line with our previous posts on the benefits of e-Prescribing software, this week we focus on the benefits of integrating e-Prescribing software with existing healthcare software programs like EHRs/EMRs (Electronic Health Record Systems and Electronic Medical Record Systems).  While several options exist for integration, here we concentrate on embedding certified e-Prescribing screens. 

 

5) Maintenance done for you

E-Prescribing requires a lot of data.  One of the main reasons to use an e-Prescribing vendor is so that the EHRs don’t have to worry about the data upkeep.  For example, MDToolbox provides a complete drug database that is updated monthly, a database for interactions, monographs and education materials that is also updated monthly, formulary information based on patients’ insurance plans that is updated weekly, and a pharmacy lookup that is updated nightly.  See more about MDToolbox’s e-Prescribing services

4) Additional Features through API

In addition to being able to add e-Prescribing to their product, there are often several other features available through the API that EHRs can add into their product.  These don’t have to be part of just e-Prescribing, they can be added wherever fits best in the EHR (by calling the API directly from EHR screens).  A few examples of some functions MDToolbox offers as part of e-Prescribing and also available to EHR screens include:

    • Allergy Search
    • Condition/Problem List Search
    • Pharmacy Search
    • Drug Research, Patient Education and Decision Support Materials

3) Meet Meaningful Use

E-Prescribing is a big part of certifying for Meaningful Use.  By adding an e-Prescribing system that already meets Meaningful Use, EHRs can focus their time on meeting the rest of the qualifications.  See which Meaningful Use criteria MDToolbox meets.

2) Faster

It can take countless development hours to design screens for e-Prescribing.  In order to electronically route prescriptions to pharmacies nationwide, you must connect to a hub.  The hubs have many rules and regulations that e-Prescribing screens must meet in order to connect.  Surescripts® (the nation’s largest hub) has strict certification requirements and the certification process can take a lot of time.  EHRs must register with Surescripts and take classes, as well as a series of tests, in order to get certified.  The process can take upwards of 4 months.  

An EHR will have a much faster time to market by embedding already certified screens.  Adding an eRx system like MDToolbox-Rx can be done in as quick as 2 weeks.  The system can be integrated and tested in one week and the next week a quick call (20 min or less) with Surescripts completes the process to go live. 

1) Cheaper

Obviously, less time spent on development equals money saved.  As mentioned above, in order to e-Prescribe, a lot of data is needed.  The cost to acquire and maintain this data can also be quite large and on-going. 

 

  • Databases – MDToolbox maintains over 200 Gigabytes worth of data that needs to be continually updated from many sources.  As an example, according to the FDA1, 5 new drug products were approved in October alone.  It is not only important to keep data updated to have the latest information available to prescribers, it is mandated to maintain status on the e-Prescribing Network.  In order to be certified through Surescripts, you must obtain approved vendor provided databases and update them regularly. 

 

  • Federal, State and Hub Requirements and Regulations - The regulations are continually being updated and new rules put in place which requires constant product and coding updates.  E-Prescribing vendors keep up with the regulations and product updates, so EHRs who have integrated with them don’t have to worry about it.  These regulations include DEA rules and individual state rules.  For example, recently the State of New York passed the “I-STOP” Laws to help the state fight prescription drug abuse.  According to a posting at nysenate.gov2, the new laws mandate medication history lookups for controlled substances, mandate ALL prescriptions be e-Sent by March 27, 2015, and updates the controlled substance schedules of many drugs to safer levels.  

 

In addition to the lower development and data costs, EHRs can also save big on certification costs. 

 

  • Surescripts® Certifications - The Surescripts certification process not only takes time, it is an additional expense.  Thousands of dollars can be saved by embedding an e-Prescribing system that is already certified.   As Surescripts® (or other hubs) come out with new rules, changes, and updates, additional product certifications for the e-Prescribing system are required.  The process is an ongoing expense.

 

  • EPCS Certification/Audits - If EHRs want to be able to electronically prescribe controlled substances, they must also go through a full DEA 1311 audit.  This can cost upwards of $15,000 dollars.  However, if an EHR adds an e-Prescribing system that has already been through the full audit, such as MDToolbox-Rx, this eliminates or greatly reduces the size and price of the audit (depending on type of integration).  Additionally, the DEA mandates that the audit be re-preformed every two years and re-audited any time the product is changed, equaling more ongoing costs.

 

Some EHRs may think the ability to create their own screens to match their system outweighs the above benefits.  However, a few e-Prescribing vendors allow customization with their screen integrations to allow for a seamless workflow.  Such things like the screen colors and fonts can be matched to the EHR's theme.  MDToolbox even allows private labeling, so an EHR can add e-Prescribing screens that completely match their current interface and their end users will have no idea that they used an e-Prescribing vendor.  So, we pose the question – With the many benefits of using already certified screens AND the ability to customize those screens, why would anyone want to go through the hard work of building and maintaining their own e-Prescribing system?

 

 

    1. “New Drugs at FDA: CDER’s New Molecular Entities and New Therapeutic Biological Products of 2013.” U.S. Food and Drug Administration, Last Updated November 5, 2013. http://www.fda.gov/drugs/developmentapprovalprocess/druginnovation/default.htm
    2. Montgomery, Velmanette. “New I-STOP Law To Help State Fight Prescription Drug Abuse.”  New York State Senate, September 6th, 2012 http://www.nysenate.gov/press-release/new-i-stop-law-help-state-fight-prescription-drug-abuse