Maine to Require e-Prescribing of Controlled Substances

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Last week the governor of Maine signed into law “An Act To Prevent Opiate Abuse by Strengthening the Controlled Substances Prescription Monitoring Program.” In addition to mandated use of the state Prescription Monitoring Program (PMP), the law will require prescribers to electronically prescribe controlled substances.

The aim of the law is to reduce opioid abuse and heroin addiction. “Heroin addiction is devastating our communities,” said Governor LePage. “For many, it all started with the overprescribing of opioid pain medications. We can prevent many people from even trying heroin in the first place by putting these limits on the flow of pain pills into our homes. I am thankful to prescribers and pharmacists who helped to craft this legislation and ultimately support it before the Legislature. They recognize that the status quo hasn’t worked and it’s time for some serious reform.”1

The law requires prescribers to do the following: 

  1. Check the state Prescription Monitoring Program prior to writing scripts for opioids or benzodiazepines
  2. Abide by prescription caps - seven days for acute pain and 30 days for chronic pain by January 2017
  3. E-Prescribe Controlled Substances by July 2017
  4. Attend addiction training every two years

This will be a big change for many prescribers. Currently, as little as seven percent of prescribers use the state PMP and according to Surescripts, less than one percent of controlled substance prescriptions were sent electronically in Maine in 2015.

Maine follows New York and Minnesota in mandating e-Prescribing of controlled substances, although Minnesota does not enforce the requirement. New York’s law, which requires e-Prescribing of both non-controlled and controlled substances, went into effect last month. Several more states have similar laws up for legislative discussion as well.

It’s clear that now is the time for anyone not e-Prescribing yet to get started. MDToolbox is offering free trials for anyone who wants to test out e-Prescribing as either a standalone solution for prescribers or an integration solution for Health IT vendors, click here for more information or contact us at 206-331-420 or info@mdtoolbox.com.

 

  1. Governor Signs Major Opioid Prescribing Reform Bill, State of Maine Office of Governor Paul R. LePage, http://www.maine.gov/tools/whatsnew/index.php?topic=Gov+News&id=675718&v=article2011

New York e-Prescribing Waivers

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With the March 27th mandatory e-Prescribing deadline in New York State looming, the New York Commissioner of Health has waived the following exceptional circumstances from the requirements of electronic prescribing1:

  1. any practitioner prescribing a controlled or non-controlled substance, containing two (2) or more products, which is compounded by a pharmacist;
  2. any practitioner prescribing a controlled or non-controlled substance to be compounded for the direct administration to a patient by parenteral, intravenous, intramuscular, subcutaneous or intraspinal infusion;
  3. any practitioner prescribing a controlled or non-controlled substance that contains long or complicated directions;
  4. any practitioner prescribing a controlled or non-controlled substance that requires a prescription to contain certain elements required by the federal Food and Drug Administration (FDA) that are not able to be accomplished with electronic prescribing;
  5. any practitioner prescribing a controlled or non-controlled substance under approved protocols under expedited partner therapy, collaborative drug management or in response to a public health emergency that would allow a non-patient specific prescription;
  6. any practitioner prescribing an opioid antagonist that would allow a non-patient specific prescription;
  7. any practitioner prescribing a controlled or non-controlled substance under a research protocol;
  8. a practitioner prescribing a controlled or non-controlled substance either through an Official New York State Prescription form or an oral prescription communicated to a pharmacist serving as a vendor of pharmaceutical services, by an agent who is a health care practitioner, for patients in nursing homes and residential health care facilities as defined in section twenty-eight hundred one of the public health law.
  9. a pharmacist dispensing controlled and non-controlled substance compounded prescriptions, prescriptions containing long or complicated directions, and prescriptions containing certain elements required by the FDA or any other governmental agency that are not able to be accomplished with electronic prescribing;
  10. a pharmacist dispensing prescriptions issued under a research protocol, or under approved protocols for expedited partner therapy, or for collaborative drug management;
  11. a pharmacist dispensing non-patient specific prescriptions, including opioid antagonists, or prescriptions issued in response to a public health emergency issued; and
  12. a pharmacist serving as a vendor of pharmaceutical services dispensing a controlled or non-controlled substance through an Official New York State Prescription form or an oral prescription communicated by an agent who is a health care practitioner, for patients in nursing homes and residential health care facilities as defined in section twenty-eight hundred one of the public health law.

Prescribers who issue prescriptions in any of these circumstances may use the Official New York State Prescription Form or issue the prescription orally. The waiver is effective until March 26, 2017. Before that time, the Commissioner of Health will reevaluate whether the e-Prescribing software available has adequate functionality for these exceptional circumstances. 

 

1. New York State Department of Health, Letter from the NYS Commissioner of Health to practictioners and pharmacists regarding a blanket waiver for additional exceptional circumstances related to electronic prescribing - March 16, 2016

http://www.health.ny.gov/professionals/narcotic/electronic_prescribing/docs/2016-03-16_blanket_waiver_letter.pdf

NY I-STOP Deadline Approaching

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The New York State Internet System for Tracking Over-Prescribing (I-STOP) Act mandates that all prescriptions, both controlled and non-controlled, be sent electronically. Last year the deadline for prescribers to meet the regulation was postponed until March 27, 2016. This new deadline is fast approaching.

In order to comply with I-STOP, prescribers must select and use a certified electronic prescribing computer application that meets all federal requirements for electronic prescriptions for controlled substances (EPCS).  This includes going through Identity Proofing and setting up 2-Factor authentication. The practitioner must also register each unique certified computer application used to electronically prescribe controlled substances with the New York State Department of Health (DOH), Bureau of Narcotic Enforcement (BNE).

The BNE recently sent out a letter to all prescribers advising the following:

“Please be aware that implementation timelines for EPCS software vary and may be lengthy. If you have not already begun this process, BNE strongly recommends that you begin immediately. Prescribers who have certified EPCS software and have completed the registration process are highly encouraged to begin electronically prescribing instead of using paper, to allow for time to resolve technical or workflow issues prior to the mandate’s effective date.”

MDToolbox has a simple signup process for both standard e-Prescribing and to setup EPCS. Most prescribers can complete the required ID proofing and 2-Factor Authentication setup within one day, but we also urge prescribers in NY to get started as soon as possible. This will ensure time to complete the application process and get all staff setup and trained.

To sign up for a free 30 day e-Prescribing trial with EPCS: New York e-Prescribing Account

Once you have signed up, you can register the application at:          

http://www.health.ny.gov/professionals/narcotic/electronic_prescribing/ropes.htm

Electronic Prior Authorization (e-PA) 101

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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

E-Prescribing of Controlled Substances Available in All 50 States

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Electronic Prescribing of Controlled Substances (EPCS) is now legal in all 50 States.  Missouri and Vermont were the last two states to authorize electronic prescribing of controlled substances.  Missouri’s regulations became effective July 30th, 2015.  Today, August 28th, Vermont became the final state to allow prescribers to legally prescribe controlled substances electronically for schedule II-V drugs.  Prescribers can now electronically prescribe controlled substances at any participating pharmacy in the United States. 

National EPCS availability is a key step in combating prescription drug fraud and abuse.  With the adoption of EPCS, patients will no longer be able to forge paper prescriptions.  Drug seeking behaviors and patterns will also be easier to identify and respond to.  With the increased electronic connectivity of pharmacies, medication histories will be more readily available.  All of these factors will also create a much safer environment for patients. 

The state of New York has passed legislation requiring prescribers to do all of their prescribing electronically starting in March next year.  As that deadline draws near and potentially other states follow, it will be necessary to stay current and have a viable EPCS solution.  Currently, the national average of pharmacies enabled for EPCS is 80.3%. Now that EPCS is legal in all states and as more states make EPCS a requirement, we expect to see more and more pharmacies coming online and allowing receipt of EPCS. 

MDToolbox offers both a certified stand-alone e-Prescribing solution, as well as an integratable solution for EHR or PM systems to add full e-Prescribing capabilities or add on just EPCS capabilities. MDToolbox is ready to help prescribers and software companies through the DEA requirements to get fully prescribing controlled and non-controlled substances electronically. Check out our EPCS page or contact us at info@mdtoolbox.com for more info.  

Less than 2% of Prescribers Utilizing EPCS

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Surescripts recently released its 2014 National Progress Report and one of the most startling findings is that only 1.4% of providers are enabled for Electronic Prescribing of Controlled Substances (EPCS).1

A much larger percent of pharmacies are setup to utilize EPCS. The national average of pharmacies enabled for EPCS is 74.9%.  A state by state comparison of the percent of pharmacies with EPCS capability, can be found on our EPCS page.

Even though EPCS is now legal in 49 states and D.C., its growth has been rather slow compared to the rates of non-controlled e-Prescribing. Surescripts’ report also found that 67%, or 1.2 billion, of all new prescriptions in 2014 were e-Prescribed. However, while there was a 400% increase in controlled substance e-Prescribing from 2013 to 2014, the number of controlled substance prescriptions was only 1.67 million.

 

Out of almost 70,000 total pharmacies and more than half a million e-Prescribing prescribers, the amount of pharmacies utilizing EPCS far surpasses the amount of prescribers.

 

While the statistics are surprising considering EPCS has been legal since 2010, there are several factors involved in the low percentage of prescribers. These include issues such as their software not being ready to meet the DEA requirements, as well as the number of steps that prescribers must go through to be setup for EPCS.

Though the steps involved may seem complex, e-Prescribing vendors are doing their best to make the process as smooth as possible for prescribers to utilize this important technology. MDToolbox has created a simple 4-step process that walks prescribers through completing the DEA requirements for EPCS that can be completed within minutes.* We also provide this EPCS solution as an integration option so that EHRs and other technology vendors can add the streamlined process to their existing workflow.

There are several benefits of EPCS including increasing patient safety and security, as well as reducing fraud and abuse. The easier it is for prescribers to setup and use EPCS, the more likely they will be to take advantage of the benefits and increase their usage.

Click here for more on EPCS for prescribers

Click here for more on EPCS for technology vendors

*Time varies based on token selection and results of identity verification

1.  2014 National Progress Report http://surescripts.com/news-center/national-progress-report-2014#public

New York Delays e-Prescribing Mandate One Year

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New York State has officially delayed the requirement to send all prescriptions electronically one year until March 27, 2016. The delay came just two weeks before the original I-STOP mandate was set to go into effect. Under I-STOP, providers will be required to send both non-controlled and controlled substances electronically. Paper prescriptions will no longer be allowed.

The main reason for the delay was stated as a lack of software vendors being ready.  While most software has the ability to electronically send non-controlled prescriptions, some are still lacking the ability to electronically prescribe controlled substances (EPCS). EPCS capability requires completing an audit by a DEA-approved auditor to prove that certain security measures are in place. 

The advantages of e-Prescribing are plentiful from patient safety to efficiency in prescribing to combatting doctor shopping. However, many of these benefits could be lost by either using software that isn’t truly ready or rushing into trying to use software that is complex. The additional time will be beneficial for prescribers. Providers can now pick the solution that is right for them without being rushed and get their practice adjusted to e-prescribing more slowly.

The delay will also take some of the pressure off those vendors who are still trying to add EPCS capabilities. While MDToolbox was one of the first vendors to be approved by the DEA for sending controlled substances, we understand the complexities involved in becoming an approved vendor. It is not an easy process. This additional year will give EHRs and other software vendors the necessary time to implement the requirements as smoothly as possible into their workflows and ensure they do not lose their providers to other vendors. Many vendors have chosen to partner with other vendors to help them meet the requirements. This is a great way to integrate EPCS and the required features such as Identity Proofing, 2-factor authentication, and Permissions without having to exert many resources. Having all of the required features come together in a package that can seamlessly integrate takes a lot of the legwork, expenses, and stress out of the process.

Whatever path vendors and prescribers choose to take, they must seize this opportunity to guarantee they are fully ready when the new deadline comes around.

Click here for further information on adding MDToolbox EPCS to your software

Click here for further information on MDToolbox standalone e-Prescribing software

Direct Messaging and Meaningful Use Stage 2 – Transition of Care

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In our previous post about Direct Messaging, we covered the major benefits of Direct Messaging. One of which being that Direct Messaging is part of Meaningful Use Stage 2 requirements. In this post we are going to dig into a few of the details behind what criteria is required for Meaningful Use Stage 2 and give a brief description of each, along with how MDToolbox helps with the criteria in our Direct Messaging system.

There are three different Meaningful Use Stage 2 criteria that require Direct Messaging:

 1) 170.314(b)(2) Transitions of care – create and transmit transition of care/referral summaries

In Stage 2, providers must be able to send Continuity of Care Documents (CCD/CDA) formatted summary files using Direct Messaging when they transition a patient or refer a patient to another provider or organization. B2 involves first creating the care summary file, which is required to have a minimum field set as well as be formatted in a certain XML format that all other health record systems will understand. And then secondly, transmitting the document via Direct Messaging. The objective requires that the messages are sent using the Direct Protocol which uses secure direct mail addresses and encryption exchange between the servers.   

Electronic Health Record systems can have a separate “Direct inbox” for sending the message or many implement a Send button right from the Chart workflow for the provider – making transfers of chart records streamlined. Some HISP/Direct Messaging vendors (like MDToolbox) offer an API or web services that allow sending the message from anywhere in the application per the EHRs needs. This allows an EHR testing on B2 to have a process that creates the care document and attaches it to a Direct Messaging email for the provider that not only meets the criteria but is a huge benefits to the end users. When the message is sent it becomes encrypted and can only be decrypted by the intended recipient’s system, keeping the patients data safe and secure.

 

 2) 170.314(b)(1) Transitions of care – receive, display and incorporate transition of care/referral summaries

In Stage 2, providers must also be able to receive these CCD/CDA and other care summary files from other providers and facilities. The first part of the criteria basically just requires having the ability to receive Direct messages. The messages can be received in a standalone inbox provided by your HISP or an embedded inbox within the EHR. Secondly, for this criteria, the EHR must be capable of displaying the received files (most of them XML formatted) in “Human Readable” or a nice formatted output for providers. The EHR needs to apply a stylesheet or other formatting so that the provider can see what was received for many types of files including the CCD/CDA, and other files like CCR (a different XML format).  And finally the criteria also involves incorporating the received attachments. The EHR must be able to upload both the document itself, and for CCD/CDA files be able to allow clinical information reconciliation of things like allergies and problem lists (allowing providers to optionally import data elements to the chart).

Electronic Health Records can incorporate an inbox right inside of the EHR with built in tools for incorporating when signing up with a HISP that offers an API/Web services (like MDToolbox). This gives huge benefits to the provider and makes this their most important (and best) inbox they monitor on a daily basis. With a few clicks, referral charts can be reviewed and filed in the electronic chart.

 

 3) 170.314(e)(1) View, download, and transmit to 3rd party

In Stage 2, patients must also have access to their CCD Summary of Care files and chart data. Not only do EHRs have to add the ability to view and download the summary from their “patient portal”, but they also need to give patients and their authorized agents the ability to securely transmit the care summary to other providers. The Transmit of the data is required to be done through direct messaging. Some third party vendors patient portals come with direct messaging, but for EHRs that have their own patient portal this becomes a challenge. EHRs must give their patients a new “Send” button that would allow entering another provider or facilities direct address and send it via the secure Direct messaging method.  

 

As thousands of providers and facilities around the country start taking advantage of the secure “Direct” messaging, it really gives them more than just a couple of check boxes on their meaningful use attestation - it’s a new and better way to transfer records, discuss patient care and communicate. It's more secure, more efficient and can be a great time saver over the traditional communication methods. 

Want more info on Meaningful Use or Direct Messaging API with MDToolbox? Check out our Direct Messaging page and contact us today at info@mdtoolbox.com

 

 Stay tuned for more posts in our 5 Part Direct Messaging Blog Series:

    1. Direct Messaging 101
    2. Top 5 Benefits of Direct Messaging
    3. Direct Messaging and Meaningful Use Stage 2 – Transition of Care (this article)
    4. How does Direct Messaging work – Details on how PHI stays secure
    5. Direct Messaging and Data Exchange:  What types of files and data can EHRs exchange?

Texas Department of Public Safety Guidelines for EPCS

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The recent rescheduling of hydrocodone combination products and the requirement to use special approved prescription paper for Schedule II drugs in Texas, has caused many prescribers to turn to e-Prescribing as an alternative. As prescribers look to this electronic alternative, there are several questions that come up as the Texas Department of Public Safety (Texas DPS) has given out some state specific guidelines. Here’s what prescribers need to know:

Is e-Sending Schedule II drugs allowed in Texas?

In October of 2013 the Texas DPS accepted the same requirements, with a few updates of their own, as the DEA in regards to sending Schedule II controlled substances electronically. 1

What are the Texas State Guidelines?

In order to comply with the Texas DPS guidelines, there are several things prescribers must be aware of and know before they start using an EPCS program. Prescribers must make sure that their vendor is certified by the DEA, meaning that they passed the required third party audit. Prescribers will also want to be sure that the vendor has EPCS capability activated for their state. Prescribers must also make sure that all their necessary credentials are included when e-Sending a prescription.

DPS, DEA and APN Numbers

The numbers prescribers now put down for paper prescriptions, their DPS, DEA and APN numbers for advanced practice nurses must also be on their electronic prescriptions as well. When prescribers are setting up their e-prescribing account they want to make sure that this information can be entered in the appropriate fields.

APNs will also enter their prescriptive authority identification number for all prescriptions written.  APNs and physicians assistants with prescriptive authority should also keep in mind they must include the DEA and DPS number of their supervising practitioner on all prescriptions schedules III-V.2

Control Numbers

Paper prescriptions written in the state of Texas for schedule II drugs require that each prescription be printed on DPS required paper that has a unique Control Number listed for the pharmacy to record. With e-prescribing all control number information, locating, and documenting is now handled entirely on the pharmacies end electronically.

What Does This Mean Now?

Texas DPS completed their beta testing of EPCS March 1, 2014. The purpose of which was to monitor Schedule II prescriptions for abuse, prescribing patterns, patients attempting to get prescriptions from multiple doctors, and fraudulent prescriptions. Also, to make sure all reporting on both the provider’s end and the pharmacy’s end was done accurately and in a timely manner.

After the results of the testing came back, the outcome was clear. Provider’s information was safer, as their DPS and DEA numbers were no longer floating around on written prescriptions for people to try to forge prescriptions with. The DPS information is also now easier and faster to track with everything being electronic. Patients’ information was also safer and relayed faster as there was no longer the constant need to rely on a phone or fax for patient information that may or may not have made it to the desired party on the other end.

Electronically prescribing controlled substances has proven to not only be a viable alternative to paper prescriptions in Texas, but an improvement. To get more information on EPCS or to start sending controlled substance electronically contact us at info@mdtoolbox.com or visit our EPCS page.

  1. https://www.pharmacy.texas.gov/EPCS.asp
  2. http://www.dps.texas.gov/RSD/ControlledSubstances/News/index.htm.

Hydrocodone Rescheduling Effective October 6, 2014

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DEA ISSUES FINAL RULING FOR HCPs TO BE RESCHEDULED FROM CLASS III TO CLASS II

The DEA has officially ruled that all hydrocodone combination products or HCPs (ex: Vicodin and Lortab) are to be rescheduled, moving them from Schedule III to II based on the Controlled Substances Act1. The ruling was made official August 22, 2014 and will be put into effect starting October 6, 2014.

 

HOW DOES THIS EFFECT PRESRCIBING?

Starting next week, all HCPs will be schedule II controlled substances (CS). This will cause several things to change and impact providers, as well as patients alike. Providers will no longer be able to write prescriptions for HCPs with refills and they will be limited to a 3 month supply at most (the rule also mandates that doctors must write the prescriptions in 30-day increments that can only be filled sequentially). Pain patients using the drugs will have to visit their doctors every three months for a new prescription. The rule also limits which providers in certain states can write these prescriptions, as well as how they can be sent.

Due to HCPs now being a schedule II CS, only practitioners registered with the DEA will be able to prescribe the drugs. However, some states have separate laws in place that limit this even further.  For example, in the states of Alabama, Georgia, Missouri, and South Carolina nurse practitioners are not allowed to prescribe, administer, or dispense schedule II CSs.

Providers are only left with two options for prescribing these schedule II drugs:

Paper Prescriptions 

According to the DEA, prescriptions for schedule II CSs cannot be phoned in or faxed to a pharmacy with the exception of emergency situations. In the case one of the situations comes to pass, the provider that authorized the emergency oral prescription has 7 days to produce a paper prescription to the pharmacy, which can be hand delivered or mailed if post marked within the 7 day period. If a prescription is faxed, it cannot be dispensed until a physical copy of the prescription is presented and reviewed. A prescription for a schedule II CS must be written with ink, indelible pencil, typed, or generated by an electronic system on tamper-proof prescription forms and hand signed if they are to be hand delivered to the pharmacy.

Electronic Prescriptions

The second way that a provider can prescribe a schedule II drug is through e-Prescribing. EPCS, or Electronic Prescribing of Controlled Substances, offers a viable solution for prescribers to not only meet the DEA requirements for schedule II prescriptions, but increase their workflow and patient safety at the same time.   With Electronic Prescriptions, the prescriber also must sign each prescription but instead of using ink, he uses a digital signature that is generated with a two-factor sign-off credential.  When the prescription is sent electronically the pharmacist can see that the order was electronically signed and knows that it came from the prescriber and was not forged.    EPCS is approved for Prescribers in 49 states for Schedule III-V and in 47 States for Schedule II drugs, meaning in most of the U.S. prescribers can use EPCS to safely send Vicodin and other schedule II drugs.

MDToolbox has made the process easy and straightforward for providers.  When a provider first signs up for EPCS, they will go through an identity proofing process and set up their two factor credentials. Once set up is complete, writing and sending a prescription for a CS is just as easy as a non CS, the only difference being entering the two-factor signing credentials that assures it is the doctor authorizing the prescription.   To get more information on how EPCS works, or to find out about signing up for our EPCS Stand Alone or EHR Integration Add on, contact us at info@mdtoolbox.com or visit our EPCS page.

 

    1. http://www.deadiversion.usdoj.gov/fed_regs/rules/2014/fr0822.htm