New CMS E-Prescribing Mandate Begins January 1st, 2021. Are you prepared?

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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 5th, 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. 


The Future of Telemedicine

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The world has seen remarkable changes this year, the methods we receive healthcare being a significant part of that change. COVID-19 has hurried the adoption of telemedicine into mainstream usage during the declared public health emergency (PHE). Legislation has now been presented to keep telemedicine as part of standard healthcare and make its usage more convenient for both providers and their patients.

President Trump’s Executive Order on Improving Rural Health and Telehealth Access

President Trump signed executive orders on August 3rd to promote the expansion of telehealth services. The Center for Medicare & Medicaid Services (CMS) outlined 135 services that are allowable via telehealth during the PHE, Trump’s executive order outlines that the services become permanently available via telehealth. The executive order also offers financial incentives for rural hospitals to continue seeing patients with a high-quality of care and directs the federal government to improve the healthcare communication infrastructure in rural areas.

“Telemedicine can never fully replace in-person care, but it can complement and enhance in-person care by furnishing one more powerful clinical tool to increase access and choices for America’s seniors,” said CMS Administrator Seema Verma. “The Trump Administration’s unprecedented expansion of telemedicine during the pandemic represents a revolution in healthcare delivery, one to which the healthcare system has adapted quickly and effectively. [1]

CMS Proposes Permanent Expansion of Telehealth

Consistent with Trump’s executive order, CMS proposed that many telehealth service payments should be expanded to be permanently covered past the PHE. A major hurdle hindering providers from adopting telemedicine as part of their practice is the disparity in the CMS reimbursement payment structure for in-person versus telehealth visits. During the PHE, CMS allowed parity in the payment structure for in-person and telehealth visits, making telehealth even more attractive for providers to participate. According to CMS, before the PHE, only 14,000 beneficiaries received a Medicare telehealth service in a week while in the last week of April, nearly 1.7 million beneficiaries received telehealth services.

Source: CMS Health Affairs Blog. Internal CMS analysis of Medicare FFS claims data, March 17, 2020 through June 13, 2020(using data processed through June, 19, 2020) Notes: Telemedicine is defined to include services on the Medicare telehealth list including audio-only visits, as well as virtual check-ins and e-visits.

Many medical providers and associations have requested that the parity remain to allow telehealth to continue growing due to the better hold on financial security. CMS is asking for input from stakeholders regarding what services should bee added to the Medicare telehealth list and the public comment period for the proposed rule is open until October 5, 2020.


Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act

Another barrier that providers are facing is the lack of inter-state licensing ability to be able to practice telemedicine for patients residing in other states. Senators Chris Murphy and Roy Blunt have presented the Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act which would grant providers the ability to treat patients in any state during and immediately following the PHE. The Act also establishes that the reciprocity can be reactivated should another PHE happen in the future, again reducing inter-state complications. Some states have reduced the requirements for providers to get a license, and some states have granted temporary licenses. Mandating nation-wide reciprocity could be invaluable to patient health during a worsening or future PHE.


DEA Telehealth Policies


The Ryan Haight Act of 2008 established regulations and prohibited healthcare providers from prescribing controlled substances to patients that they haven’t first examined in-person. Section 802(54)(D) of the Controlled Substances Act allows for the Ryan Haight Act to be circumvented during a public health emergency which the DEA invoked on March 16, 2020. This currently allows MDToolbox users to electronically prescribe controlled substances (EPCS) for patients via telemedicine. Patients must be evaluated using a real-time, two-way, audio-visual communications device.

The DEA has missed several deadlines to establish rules and a waiver system to allow electronic prescribing of controlled substances via telemedicine when there is not a PHE. Reducing these road-blocks, as we are seeing with the emergency measures in place due to COVID-19 can help bring healthcare into the 21st century and help reduce stress on our medical system and patients.

DEA State Registration

The DEA has also waived the requirement for state-specific registrations during the PHE. The exception to separate registration requirements across state lines was issued March 25, 2020 and allows prescribers who are registered in at least one state to prescribe controlled substances to patients in other states via telemedicine.

Opioid Use Disorders

The DEA, in partnership with the Substance Abuse and Mental Health Services Administration (SAMHSA), also stated that it is allowing authorized providers to prescribe buprenorphine to new and existing patients with Opioid Use Disorder (OUD) via only telephone voice calls without first requiring an examination of the patient in person or via telemedicine. This exception is only during the PHE and prescribing practitioners must be DATA-waived.


Telehealth Response for E-prescribing Addiction Therapy Services (TREATS) Act

Not to be confused with the earlier mentioned TREAT act, the Telehealth Response for E-prescribing Addiction Therapy Services (TREATS) Act was introduced by Senators Rob Portman (R-OH) and Sheldon Whitehouse (D-RI) and looks to make some of the telehealth substance use disorder (SUD) treatment changes permanent.

The bill adds to and replaces language in the current Telehealth for Substance Use Disorder Treatment codes. The changes would allow a Schedule III or IV medication to be prescribed for the purpose of treatment for an Opioid Use Disorder via “1 in-person medical evaluation or 1 telehealth evaluation”.  The bill then clarifies that the “1 telehealth evaluation” shall not be construed to imply that a single telehealth evaluation demonstrates the usual course of professional practice. The medical provider will need to continue follow-up and management of the patient and medication after the initial in-person or telehealth visit per current guidelines.

Continue to follow our blog and social media for information related to telehealth and electronic prescribing. MDToolbox looks forward to providing tools and resources to assist telemedicine providers throughout the United States to ease the transition, helping our customers increase the efficiency of their office and combat the opioid epidemic. With MDToolbox, prescribers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS), the ability to check most State’s PMPs without having to separately login to their State portal, and convenient on the go e-prescribing with our mobile app! We offer a free 30 day free trial, so Contact us for more information!



Benefits of Electronic Prescribing Software for Telemedicine

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2020 has seen massive growth for telemedicine due to the pandemic. Many much-needed policy changes have been put in place in response, including allowing prescribers to prescribe both non-controlled and controlled medications to patients without first seeing them in person during the public health emergency. The CDC has also issued guidelines recommending telehealth to expand access to essential health services during and beyond the COVID-19 pandemic. Stay tuned as we will dive further into the policies and other proposed changes next week. In this post, we focus on the many benefits of e-prescribing in telemedicine.

The increase in patient access to healthcare via telemedicine is a powerful tool, one that appears to be highly desired by patients. A recent report presented by the Department of Health and Human Services detailed that 43.5% of Medicare fee-for-service primary care visits were conducted via Telemedicine in April of this year, up from just .1% of visits in February before the public health crisis had been declared.

Electronic prescribing has many advantages for prescribers practicing telemedicine and telehealth. Sending prescriptions electronically can drastically improve a prescriber’s workflow by being able to transmit prescriptions to the pharmacy quickly and efficiently, avoiding the traditional stresses of mailing a paper prescription, making phone calls, or dealing with pages of faxes so that remote patients can receive their medications.

Here are five ways MDToolbox offers one of the best e-Prescribing software services to save telemedicine practices time & money:

1. Electronic prescribing will improve the safety and quality of care that providers can provide patients.

E-prescribing can reduce drug errors by eliminating handwriting and illegibility issues with prescriptions, sending the prescription digitally ensures the order is clear.  Some electronic prescribing systems (such as MDToolbox) allow for pulling medication fill history for patients automatically, so even if the patient cannot recall their medications, the prescriber will have quick access to a record of it. MDToolbox can improve patient safety by alerting for any drug to drug interactions, drug allergy interactions, drug to condition interactions, and duplicate therapy conditions. These alerts could save a patient’s life.

2. With MDToolbox, patient medication history can be checked in as little as one click.

The opioid epidemic plaguing our country has resulted in many states mandating checking the state specific Prescription Drug Monitoring Programs (PMPs) prior to prescribing certain controlled substance medications. MDToolbox allows prescribers in most states to be able to check this data directly within the prescription writer, saving prescribers time so they can move on to their next virtual visit quickly and efficiently.

3. Satisfy Medicare MIPS requirements by meeting Meaning Full use.

MDToolbox is certified to meet Meaningful Use requirements necessary for the Merit Based Incentive Payment System (MIPS).  By using MDToolbox, prescribers are able to increase their scores and maximize their payment adjustments received by Medicare.  Please see our Meaningful Use Certification page for specifics on certifications.

4. Electronic prescribing saves patient’s money and increases patient satisfaction.

MDToolbox allows for viewing the price of the specific medication the provider is prescribing at their patient’s specific pharmacy as they are writing the prescription. The system will present potential alternatives that may save the patient money by making a brand or pharmacy change. This could also save the practice valuable time avoiding a patient calling back to change pharmacies if they find the price too high where the medication was prescribed.

5. Meet State and National mandates to electronically prescribe.

States are continuing to pass legislation requiring all prescribers to send electronic prescriptions. Arkansas, Colorado, Delaware, Indiana, Kansas, Kentucky, Massachusetts, Missouri, Nevada, South Carolina, Tennessee, Texas, Washington, and Wyoming have mandates going into effect in 2021. See our State Map for information on current and pending legislation. Some States detail extensive penalties for not complying with their electronic prescribing legislation. In addition, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act will require EPCS at the national level starting in January 2021.

MDToolbox looks forward to providing tools and resources to assist telemedicine providers throughout the United States to ease the transition, helping our customers increase the efficiency of their office and combat the opioid epidemic. With MDToolbox, prescribers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS), the ability to check most State’s PMPs without having to separately login to their State portal, and convenient on the go e-prescribing with our mobile app! We offer a free 30 day free trial, so Contact us for more information!