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

Top 5 Benefits of Direct Messaging

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Last week we covered the basics of what Direct messaging is in the healthcare field.  This week we focus on some of the biggest benefits of using Direct messaging. 

1.     Improves Care Coordination

By eliminating the need for outdated communication methods, such as faxing and mailing, and enabling electronic health information exchange with Direct messaging, communication is greatly improved between health care providers. Protected Health Information (PHI) is not only easier to send and receive electronically, but faster.  Instead of waiting for a fax or even worse, snail mail, Direct messaging allows for sending and receiving information almost instantaneously, increasing the efficiency and effectiveness of care coordination. 

2.     Secure

Faxes and envelopes could fall into the wrong hands.  Direct messaging increases the security of sending PHI information by encrypting messages and files and ensuring they are only accessible by the intended recipient.   

3.     Increases Workflow

When a patient’s information is sent by mail or fax, it still needs to be manually entered into the provider’s EHR.  By sending the information electronically, Direct messaging eliminates the need for this data entry and reduces the administrative workload.  Providers can spend more time with their patients, and less time on paper charts. 

Some Direct messaging systems, like MDToolbox-Direct, can also be integrated right into an EHR's workflow.  This increases the workflow even further by allowing providers to send and receive Direct messages in their EHR without having to log into a separate system, as well as incorporate any received information into the patient’s chart right at the time of receiving it. 

4.     Saves Money

In addition to the time saved with Direct messaging, providers can also save money by not having to pay for faxing or postage.  Furthermore, with the improved communication between providers that Direct messaging provides, duplicate procedures and tests can be avoided. 

5.     Reduces Errors

Direct messaging ensures clear and more complete information reaches the correct locations. Illegibility issues due to faxing or handwriting are eliminated by sending the information electronically and providers can be confident the information they send and receive is accurate.

Another huge benefit (and a main factor in the growth of Direct messaging) that we left off this list is that using Direct messaging meets Meaningful Use Stage 2 requirements.  We want to feature this benefit and so in our next Direct messaging blog series post, we delve into this topic in great detail.  Here’s a look at what other topics we have in our series:

5 Part Direct Messaging Blog Series: 

  1. Direct Messaging 101
  2. Top 5 Benefits of Direct Messaging (this article)
  3. Direct Messaging and Meaningful Use Stage 2 – Transition of Care
  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?

Direct Messaging 101

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At MDToolbox, we focus on providing easy-to-integrate Meaningful Use tools.  We recently expanded our product offerings to include MDToolbox-Direct, a Direct Messaging Module that meets Meaningful Use Stage 2 criteria.  With our flagship product, MDToolbox-Rx, we focus on sending and receiving e-Prescribing messages between providers and pharmacies.  We are excited now to be able to facilitate a different type of messaging - Direct messaging.  So, what exactly is Direct messaging?

What is Direct Messaging?

Direct Messaging is a secure way for healthcare providers and organizations to send clinical messages and exchange Protected Health Information (PHI).  Providers and organizations can send secure electronic messages to each other, including attachments such as Continuity of Care Documents (CCD) files, Referral Documents, images such as X-rays, and other types of medical files.  This eliminates the need for using less secure methods that can put patient data at risk such as faxing, e-mailing, phoning, or standard mail. 

How is Direct Messaging different than email?

Direct messaging sounds very similar to regular email, and generally speaking, it is.  Providers and organizations have a Direct address (just like an email address) that they send and receive messages to/from.  However, there are some very important differences.  Direct messaging requires all users to have a designated Direct address that can send and receive authenticated, encrypted messages.   All messages and attachments sent must meet certain encryption standards that allow only the intended recipient(s) to decrypt and read the messages and attachments.  These standards were developed by the Office of the National Coordinator for Health Information Technology (ONC) as part of the Direct Project.

What is the Direct Project?

The Direct Project is an open government initiative that was started in 2010.  The purpose of the Direct Project is to create a set of technical standards, protocols, and services for secure, point-to-point electronic healthcare messaging.  The ultimate goal is to create advanced levels of interoperability by having all healthcare systems use the same Direct standards and protocols. This will make it is easy for healthcare providers and organizations to directly exchange information, no matter what software system they are using.  For further information on the Direct Project and the specific technical requirements, check out http://directproject.org/ 

How do I get Direct Messaging?

Organizations called Health Information Services Providers (HISP) provide the Direct addresses to providers and organizations and facilitate the encrypted messaging.  So instead of an email provider like Google or Outlook handling the message exchange, a HISP is responsible for securely routing and encrypting/decrypting the messages.  MDToolbox has partnered with Surescripts, a trusted industry leader, to provide HISP services and our MDToolbox-Direct module can be utilized stand alone for providers and organizations or easily integrated with EHRs and other Health IT systems. To find out more contact us at info@mdtoolbox.com or use our contact page

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

  1. Direct Messaging 101 (this article)
  2. Top 5 Benefits of Direct Messaging
  3. Direct Messaging and Meaningful Use Stage 2 – Transition of Care
  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?

Meaningful Use Stage 2 Status

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Meaningful Use Stage 2 started at the beginning of the year and it has been off to a slow start. A report from CMS last month showed that only 50 eligible professionals (EPs) had attested to Stage 21.  While the latest numbers given have increased to 447 EPs that have attested to Stage 2, this is still a relatively small number.2  Such low numbers point towards a lack of certified products. 

A review of the ONC HIT’s Certified Health IT Product List shows that there were over 3,500 products certified for Ambulatory Stage 1 and only a little over 700 are certified for Ambulatory Stage 2.  It is also interesting to note that out of 988 developers who certified products for Stage 1 (many had several different products, even hundreds), there are only 312 vendors with Stage 2 products.  Of those vendors with Stage 2 products, only 140 have complete EHRs that meet all of the criteria for attesting to Stage 2.  

 

Only a fraction of products, complete EHRs, vendors, and complete EHR vendors have certified for Meaningful Use Stage 2 compared to those that certified for Stage 1 as of June 13, 2014

 

CMS has proposed a potential delay in the requirement of all providers to use a 2014 Stage 2 certified product this year.3  If the pending rule passes, then providers will have one more year to use their stage 1 product.  This would also give EHRs extra time to get their product certified for the harder Stage 2 criteria.  The proposed rule is only for 2014, EPs would be required to use 2014 Edition CEHRT for the EHR reporting periods in 2015.  The rule is open for comments until July 21. 

If the rule passes this gives EHRs more time to meet the new criteria of stage 2 and get their product certified.   If it doesn’t pass, providers wanting to attest this year that do not have a Stage 2 certified product may be out of luck.  In order to attest to Stage 2 this year, physicians must report for 90 days.  As it is now, those attesting to Stage 1 for the first time need to report for 90 days before October 1st, 2014 in order to avoid the 1% Medicare penalty next year.  This means they would need to start by July 1st, only a little over a week away and before the proposed rule could be finalized. 

As a vendor who recently achieved ONC HIT 2014 Edition Modular EHR certification for our e-Prescribing product, MDToolbox-Rx, we understand how challenging meeting the Stage 2 requirements can be.  Because of this, we hope that the pending CMS rule is approved to give other vendors and providers the extra time they need to meet the criteria. 

MDToolbox offers meaningful use tools to help vendors quickly and easily meet some of the most challenging criteria.  EHRs who integrate our meaningful use certified e-Prescribing module can cross 9 criteria off their list and inherit our certification number towards their Complete EHR.   MDToolbox has also added a new MU2 Direct Messaging Module, MDToolbox-Direct, to our product line.  The Direct messaging module allows sending secure clinical messages via the Surescripts network that meet Meaningful Use Transition of Care and View, Download, Transmit criteria.   Contact us today to find out more about how we can help you get Stage 2 certified.

 

 

  1.  http://www.healthit.gov/FACAS/sites/faca/files/HITPC_CMS_Update_2014-05-06.pdf
  2.  http://www.healthit.gov/facas/sites/faca/files/HITPC_CMSUpdate_2014-06-10.pptx
  3. CMS rule to help providers make use of Certified EHR Technology http://www.cms.gov/newsroom/mediareleasedatabase/press-releases/2014-press-releases-items/2014-05-20.html

Top 8 Acronyms You Need to Know for Meaningful Use

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Previously we covered important Meaningful Use Terms you need to know.  But, as it seems to be with any topic, there are several acronyms you need to know to understand Meaningful Use and the requirements as well.  To help you get started, here are our top 8:

 

ONC - Office of the National Coordinator for Health Information Technology

The ONC is the department within the U.S. Department of Health and Human Services that is in charge of Meaningful Use and promoting EHR use. 

 

NIST - National Institute for Standards and Technology

NIST is the agency within the U.S. Commerce Department that is in charge of creating the Meaningful Use test methods that EHRs use to certify on.  The agency creates standards for several other areas as well, including the Security Controls and ID Proofing needed for Electronic Prescribing of Controlled Substances (EPCS).

 

HITECH Act - Health Information Technology for Economic and Clinical Health Act

The HITECH act was signed into law in 2009 and is the act stipulating incentive payments be paid for Meaningful Use to eligible providers.

 

EP - Eligible Provider

EPs are healthcare providers that are eligible to attest to Meaningful Use.  The Medicare and Medicaid programs have different types of EPs:

Eligible Medicare EPs include:

  • Doctors of Medicine or Osteopathy
  • Doctors of Dental Surgery or Dental Medicine
  • Doctors of Podiatric Medicine
  • Doctors of Optometry
  • Chiropractors

Eligible Medicaid EPs include:

  • Physicians
  • Nurse Practitioners
  • Certified Nurse - Midwife
  • Dentists
  • Physicians Assistants who practice in a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC) that is led by a Physician Assistant

 

CDS - Clinical Decision Support

CDS can be a number of different tools in an EHR that offer healthcare providers patient-specific information to aid in their clinical decisions and is one of the requirements for attesting to Meaningful Use.  A good example of CDS is showing a drug-drug or drug-allergy alert when a provider selects a drug that could have an interaction for the patient.

 

CPOE - Computerized Physician Order Entry

CPOE is the process of electronically entering medical orders, instead of on paper charts, and is also a requirement for attesting to Meaningful Use.  A prime example is electronically entering a prescription, instead of writing it out by hand on a prescription pad. 

 

HIE - Health Information Exchange

HIE is the electronic exchange of health information.  It allows health care providers and patients to access and share a patient’s health records electronically.  One of the main goals of Meaningful Use Stage 2 is to increase HIE between providers in order to increase care coordination and patient outcomes.

 

C-CDA – Consolidated-Clinical Document Architecture

The C-CDA format is a specific format standard that allows EHRs to exchange patient data with each other.  

Top 4 Terms for Meeting Meaningful Use

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In our last post, we covered why Meaningful Use is so big in 2014.  When talking about Meaningful Use, there are a lot of terms and requirements that are thrown around and it can get quite confusing.  This week we delve a little deeper into some of the main terms and requirements for meeting Meaningful Use.

1.       Attestation

Meaningful use attestation is the process of demonstrating that an individual or organization is meeting the requirements in order to qualify for the federal government payments.  They must prove (attest to) that they are meaningfully using a certified EHR.  Providers are required to register and attest using the Centers for Medicare & Medicaid Services (CMS) website.  As we mentioned last week, there are three different stages to Meaningful Use and providers must attest annually to whichever stage they are on.  There are three sets of requirements providers must attest to at each stage:  core objectives, menu objectives, and clinical quality measures.

2.       Core Objectives

Each stage of Meaningful Use has its own set of Core Objectives that a provider must meet and attest to.  All Core Objectives are required and have a specific measurement for each objective that must be achieved.  For Stage 1 there are 15 Core Objectives and for Stage 2 there are 17 Core Objectives.  As providers move on to the next stage, the measures get higher and/or include more requirements. 

Here’s an example:

            Core Objective:   Generate and transmit permissible prescriptions electronically (eRx)

Stage 1 Measure:  More than 40% of all permissible prescriptions written by the EP (Eligible Provider) are transmitted electronically

Stage 2 Measure: More than 50% of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using CEHRT.

3.       Menu Objectives

In addition to the Core Objectives, providers also have to meet and attest to a set of Menu Objectives.  Not all Menu Objectives are required, and providers are allowed to choose a certain number from the set.  In Stage 1, providers must attest to 5 out of 10 Menu Objectives, with at least 1 public health objective selected.  In Stage 2, providers must attest to 3 out of 6 Menu Objectives. 

Here’s an example:

            Stage 1 Menu Objective: Medication reconciliation

Measure:  The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP.

Stage 2 Menu Objective: Record electronic notes in patient records.

Measure: Enter at least one electronic progress note created, edited and signed by an EP for more than 30 percent of unique patients with at least one office visit during the EHR reporting period.

 4.       Clinical Quality Measures

Lastly, providers must attest to a set of Clinical Quality Measures (CQMs).   CQMs look at how well a provider delivers appropriate clinical services to their patients, or the quality of care.  They assess everything from treatments to experiences to outcomes.  As stated on the CMS website, “CQMs help identify areas that require improvement in care delivery, identify differences in care among various populations, and may improve care coordination between health care providers.” 

As of 2014, all providers have to report on the same CQMs regardless of what stage they are on.  There are 64 CQMs categorized into six National Quality Strategy domains which include: (1) Patient and Family Engagement (2) Patient Safety (3) Care Coordination (4) Population/Public Health (5) Efficient Use of Healthcare Resources and (6) Clinical Process/Effectiveness.  Providers must report on 9 of the 64 CQMs and they must cover at least three of the National Quality Strategy domains.  Providers are only allowed to attest to CQMs that their EHR vendor has certified on, so some providers might have a lot less than 64 to pick from. 

Here’s an example:

Clinical Quality Measure: Documentation of Current Medications in the Medical Record

Measure Description: Percentage of specified visits for patients aged 18 years and older for which the eligible professional attests to documenting a list of current medications to the best of his/her knowledge and ability

Domain: Patient Safety

 

Source:

www.cms.gov

Meaningful Use in 2014 – What’s All the Fuss About?

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“Meaningful Use” is one of the biggest healthcare buzz terms in 2014, so what’s all the fuss about? Our next series of blog posts is dedicated to answering this, and other questions, about Meaningful Use.

Meaningful Use - The Basics

Meaningful Use was established by the Centers for Medicare & Medicaid Services (CMS) in 2011 as an incentive payment program to encourage the appropriate use of electronic health records (EHR).  The goal of the program is to improve patient care by “meaningfully using” EHRs to meet the following five priorities:

    1. Improving quality, safety, efficiency, and reducing health disparities
    2. Engaging patients and families in their health
    3. Improving care coordination
    4. Improving population and public health
    5. Ensuring adequate privacy and security protection for personal health information

 

Meaningful Use Stages

CMS has established certain objectives that healthcare providers must meet in order to receive incentive payments (and avoid penalties).  There are 3 stages to the program, with increasing requirements for participating:

  • Stage 1

Providers begin by meeting Stage 1 requirements for a 90 day period within the first year.  Then, depending on the year they started, they must demonstrate 3 months or a year of Meaningful Use in their second year.

The focus of Stage 1 is data capture and sharing, with five main areas:

  1. Electronically capturing health information in a standardized format
  2. Using that information to track key clinical conditions
  3. Communicating that information for care coordination processes
  4. Initiating the reporting of clinical quality measures and public health information
  5. Using information to engage patients and their families in their care
  • Stage 2

Once a provider has achieved Meaningful Use under the Stage 1 criteria, they move on to Stage 2 for two years.

The focus of Stage 2 is advanced clinical processes, with four main areas:

  1. More rigorous health information exchange (HIE)
  2. Increased requirements for e-prescribing and incorporating lab results
  3. Electronic transmission of patient care summaries across multiple settings
  4. More patient-controlled data
  • Stage 3

The focus of Stage 3 is improved outcomes, with five main areas:

  1. Improving quality, safety, and efficiency, leading to improved health outcomes
  2. Decision support for national high-priority conditions
  3. Patient access to self-management tools
  4. Access to comprehensive patient data through patient-centered HIE
  5. Improving population health

 

Why is 2014 Such a Big Year for Meaningful Use?  

  • Stage 2 Began

2014 is the first year that Stage 2 criteria have been effective and any providers who began Stage 1 in 2011 or 2012 are now required to begin Stage 2. 

  • Last Year to Start Earning Incentives

2014 is the last year that a provider can start participating and earn any EHR incentives.  If a provider starts participating in 2014, they can still earn up to $24,000 in incentives.  In addition, providers must successfully demonstrate meaningful use by October 1, 2014 to avoid a 1% Medicare penalty in 2015.  In 2016, the penalty increases to 2% and then increases again to 3% in 2017.   

  • 2014 Certified EHR Technology Required

In 2014, all providers are required to attest to meaningful use using only 2014 Certified EHR Technology, regardless of what stage they are on.  Because of this, all providers are only required to demonstrate meaningful use for a 3-month EHR reporting period.  This is to allow providers sufficient time to upgrade their systems to the necessary technology. 

This also means that all EHRs being used for Meaningful Use have to be recertified using the 2014 criteria by July 1, 2014 in order to allow providers to attest by the October 1st deadline.

 

Sources:

www.cms.gov

www.healthit.gov

EPCS Status Update

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With only three states left to approve EPCS and a few others working on their final requirements, EPCS is gaining great traction in 2014.  As more and more pharmacies come online every day, MDToolbox is excited to be at the forefront of helping HIT vendors and physicians take the next step – and send ALL prescriptions electronically.     

What states are we still watching? 

And then there were 3 - Arkansas, Montana, and Rhode Island

Arkansas, Montana, and Rhode Island are the three states where EPCS still remains unavailable as their state governments sort out the differences in the State Laws versus the DEA rulings.  Arkansas made progress by passing Act 1331 in April of 2013 to clarify that electronic prescribing of controlled substances is permitted.  Furthermore, the Arkansas State Board of Pharmacy had a public hearing scheduled to discuss the changes in February 2014, but it was postponed until March due to poor weather conditions.  Rhode Island also passed a similar bill, SB 647, in June of 2013 which states, “A practitioner may sign and transmit electronic prescriptions for controlled substances.”  However, further clarification is still needed from all three states before EPCS is allowed.  Stay tuned as we will post any updates as soon as we get them!   

Oregon

While Oregon is listed as allowing Schedule II-V substances to be sent electronically on the Surescripts map, Schedule II substances can actually only be legally e-Prescribed in emergency situations.    A bill was introduced on February 3, 2014, that if approved would allow all controlled substances including Schedule II drugs to be electronically sent in non-emergency situations as well.

New York

All eyes are on New York as they are leading the way by being the first state to mandate that all prescriptions be sent electronically.  It was almost a year ago that EPCS became legal in the state of New York.  As of March 27, 2013, amendments to Title 10 NYCRR Part 80 Rules and Regulations on Controlled Substances went into effect, technically allowing providers in New York to electronically prescribe Schedule II-V drugs1.  However, the actual implementation of EPCS has been slower than expected as the state of New York was overdue finalizing its registration process.  Pharmacies and providers are still currently struggling to meet all the requirements. 

It was not until January 23, 2014 that Surescripts was able to turn on EPCS functionality for the State of New York.  Currently, out of 5,579 registered New York pharmacies there are only about 850 listed as being able to receive electronic controlled substance prescriptions on the Surescripts network.  As we mentioned in our post about the Evolution of EPCS, pharmacy software must go through a DEA Certification or third-party audit to verify they comply with the strict regulations put in place by the DEA and through a Surescripts certification.  In addition, pharmacies in New York are also required to submit dispensing data for controlled substances using the American Society for Automation in Pharmacy (ASAP) format Version 4.2 or greater2

It is not only the pharmacies in New York that have to go through extra steps to use EPCS, the prescribers do as well.  The New York State Department of Health, Bureau of Narcotic Enforcement (BNE) recently released registration packets that are required for each prescriber who would like to transmit electronic prescriptions for controlled substances.  All prescribers must register their electronic prescribing software and be able to provide proof of a DEA certification or third party audit verifying the software meets the federal security requirements for transmitting controlled substance prescriptions electronically.  The DEA requires that all prescribers go through strict identity proofing and receive two-factor authentication credentials for EPCS.  Prescribers must attest that they have personally met these federal requirements when registering with the BNE as well. 

With the New York I-STOP Law mandating that ALL prescriptions be electronically sent by March 27, 2015 with limited exceptions, providers only have a little over a year to register and begin using EPCS certified software.

MDToolbox is prepared and ready to help any providers meet this fast approaching deadline.   We are currently offering free EPCS software tokens for a year to any providers that sign up.  Check out our EPCS page and contact us at info@mdtoolbox.com for more information. 

 

  1. https://www.health.ny.gov/regulations/recently_adopted/docs/2013-02-13_electronic_prescribing_dispensing_and_recordkeeping_of_controlled_substances.pdf
  2. https://www.health.ny.gov/professionals/narcotic/electronic_prescribing/

 

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