Electronic Prescriptions for Controlled Substances becoming a standard across the country
EPCS is increasingly becoming a standard across the United States, and if your state does not yet require it, chances are it will soon. It’s important to be aware of this rule and know how it will impact your practice and your patients.
EPCS: A short history
EPCS is short for Electronic Prescribing of Controlled Substances. The rule was born out of the federal Controlled Substances Act of 1970, back when most prescriptions and almost all medical notetaking and recordkeeping were performed on paper. The law was meant to ensure an adequate supply of controlled substances for legitimate medical, scientific, industrial, and research purposes while discouraging their diversion from legitimate channels to illegal ones. The law created a closed system for the manufacture, distribution, and dispensing of controlled substances, and included a provision for record-keeping along with rules for the manual signing of controlled substance prescriptions.
In 1999, as more systems went online and digital, the Drug Enforcement Agency began to study how its regulations would allow the use of electronic systems. A rule was published in 2005, with regulations modified in 2010 that lifted previous restrictions which prohibited the use of electronic prescribing for controlled substances. Today, electronic prescribing is widely seen as the industry standard, helping to reduce paperwork for pharmacies and providers, lower the rates of prescription forgery, and help integrate prescription records with electronic medical records systems.
Benefits of electronic prescriptions for controlled substances
Electronic prescriptions have distinct advantages when it comes to controlled substances. They include:
- Improved patient safety: Electronic systems include safeguards against allergies, interactions, improper dosing, and patient conditions such as pregnancy and breastfeeding.
- Workflow efficiency: Electronic prescriptions do away with the need to write out prescriptions by hand, which eliminates an additional step and saves time.
- Improved security: Since electronic prescriptions go directly from the doctor to the pharmacy, there is no opportunity for the patient to alter the quantities or number of refills, or view the physician’s DEA number, which protects the provider from fraud.
- Reduced costs: Providers can see before issuing a prescription if the patient’s insurance plan will cover the medication. If not, it may be possible to prescribe an alternate medication.
- Reduced doctor shopping and drug abuse prevention: Because electronic prescriptions may include a medication history, physicians can see the patient’s medication history and identify signs of abuse.
- Other benefits, including interoperability, improved patient satisfaction, and insight into controlled substance prescriptions.
Despite obvious benefits, adoption of EPCS has been slow
Despite the long list of benefits to both providers and patients, the adoption of electronic prescriptions of controlled substances has been surprisingly slow. The reasons primarily center on cost concerns, cumbersome technology, and the security specification that the DEA requires.
The new mandates were also seen as an inconvenience to providers and something that could disrupt workflows.
None of those concerns, however, seem to play out. For example, according to user reports, e-prescribing reduces the amount of time spent on each controlled substance prescription from as much as 5 minutes to as little as 30 seconds. It has also been shown to save on healthcare costs for providers and patients, as well as increase medication adherence. E-prescribing also greatly reduces the amount of time that providers and pharmacists spend on the phone, sending scripts to pharmacies.
States develop their own EPCS mandates
In 2018, Congress passed the SUPPORT for Patients and Communities Act. The law included legislation that required Medicare Part D practitioners to begin electronically prescribing Part D drugs requiring prior authorization on or before Jan. 1, 2021. Medicare Part D prescribers in every state are subject to the rule and must comply.
Meanwhile, many states began developing their own Electronic Prescribing for Controlled Substances laws to standardize the prescribing practices across all providers.
Which states currently require EPCS?
Currently, about half of the states have already rolled out their own EPCS requirements or are in the process of doing so. This can be confusing since prescribers like doctors, dentists, and nurses are already required to use EPCS for all controlled substances under Medicaid Part D.
Not all state mandates are identical, with the details of each state’s rules differing depending on factors such as the specific schedules that must be electronically prescribed. Prescribers should be aware of the schedules of controlled substances required under their state’s EPCS mandate and act accordingly.
These states had their own EPCS system in place by January 2021:
- Arizona
- Connecticut
- Florida
- Iowa
- Maine
- Massachusetts
- Minnesota
- New Jersey
- New York
- North Carolina
- Ohio
- Oklahoma
- Pennsylvania
- Rhode Island
- Tennessee
- Virginia
In addition, the following states will enact EPCS systems during 2021.
- Arkansas
- Colorado
- Delaware
- Indiana
- Kansas
- Kentucky
- Missouri
- Nevada
- South Carolina
- Texas
- Washington
- Wyoming
Meanwhile, as of September 2021, the following states had no current or pending EPCS mandate:
- Alaska
- Hawaii
- Oregon
- Idaho
- Montana
- Utah
- New Mexico
- Nebraska
- South Dakota
- North Dakota
- Louisiana
- Mississippi
- Alabama
- Georgia
- Wisconsin
- Illinois
- Ohio
- West Virginia
- New Jersey
- New Hampshire
- Vermont
It is worth noting that Michigan has an upcoming mandate deadline that goes into effect on Oct. 1, 2021. California, Indiana, Maryland, Nebraska, New Hampshire, Utah, and Washington will require EPCS beginning on Jan. 1, 2022.
PDMP overview for providers
PDMP is short for “prescription drug monitoring program.” It is an electronic database that tracks controlled substance prescriptions. When used, it can help identify patients who may be misusing or abusing prescription opioids or other prescription drugs.
PDMPs allow providers to access patient history and resources that help them analyze prescription fill patterns more comprehensively. The information that these tools produce creates additional opportunities that providers can use to discuss concerns about addiction or abuse of prescription medications with patients.
A total of 49 states plus the District of Columbia and Guam have active PDMP databases that collect and report prescribing and dispensing data. The only state without one is Missouri; an executive order was signed by the governor of Missoula to create a PDMP in 2017, but there is not yet an active statewide system. A new law creating a PDMP in Missouri was signed earlier in 2021.
A blend of rules to follow: Are you prepared to handle mandates?
Providers and those prescribing medications could be forgiven for finding this mishmash of rules confusing. The blend of local, state, and federal rules makes both EPCS and associated PDMP rules challenging to follow — yet it remains critical to do so. Early indications also suggest that EPCS will soon be required in every state and territory in the nation at some level, especially given its requirements for Medicaid compliance. Healthcare systems and providers that adopt EPCS mandates now will be better positioned to provide enhanced patient services and take advantage of the benefits of going digital.
Mandate certifications such as HITRUST and HHS for EHR solutions are critical for practices that want to maintain modern workflows and receive the payments they are due – without it, they won’t get paid. HITRUST certification shows that a practice has applied appropriate administrative, technical, and physical safeguards and demonstrates compliance with HIPAA requirements. Like EPCS, it’s one tool that can be used to protect patients and practices against established and emerging threats.
Eye Care Leaders ensures that your practice adheres to all the requisite certifications, and can help you adhere to existing state EPCS rules and prepare for those that may be coming online soon. To learn more about EPCS, Hitrust, and more, contact Eye Care Leaders today.
