Electronic prescriptions are becoming standard, replacing paper prescriptions in most practices. As a result, federal and state governments are looking for ways to use the electronic prescribing of controlled substances (EPCS) to help battle the growing problem of drug abuse and dependence. In this post, we explore what EPCS regulations are and your responsibilities as a psychiatrist.
What is EPCS?
E-prescribing for controlled substances (EPCS) was approved by the Drug Enforcement Agency (DEA) in 2010. EPCS allows a provider to send a prescription for a controlled substance directly to a pharmacy from a device like a laptop, tablet, or desktop computer instead of using a paper script or calling the prescription in to a pharmacy. A compliant EHR software program is used to safely and securely transmit the prescription for these drugs, regulated by the Controlled Substance Act (CSA) .
Now, ten years after e-prescribing was approved, prescribers are not only encouraged to use electronic transmission for controlled substances, but are now mandated to do so in many states. EPCS mandates intend to eliminate paper prescriptions, requiring prescribers to write e-prescriptions for all controlled substances, including psychiatric medications.
Why are EPCS Regulations Beneficial?
The EPCS regulations resulted from a desire to reduce deaths from drug overdoses. There are many benefits of electronic prescribing for controlled substances, including:
- Making controlled substance prescriptions digitized and trackable by the pharmacy and the prescriber
- Improving convenience for providers and patients as prescriptions are sent electronically directly to the pharmacy for initial and refill requests
- Reducing medication errors though improving prescription accuracy
- Checking for drug interactions, improving patient safety and healthcare quality
- Eradicating forged or stolen paper prescriptions
- Saving time for patients waiting at pharmacies for their prescription
- Increasing security by requiring prescriber authentication and activity auditing
Since all e-prescriptions are trackable, addicted patients can no longer “doctor shop” to get controlled substance prescriptions from a number of different providers without the activity being flagged and noticed. E-prescribing also eliminates people stealing prescription pads and forging prescriptions, further reducing the risk of misuse seen with the paper prescription system.
Who Do EPCS Regulations Apply to?
The federal EPCS mandate will take place in January 2021, requiring e-prescribing for controlled substances for the Medicare Part D program. Several states, including Arizona, Massachusetts, North Carolina, Oklahoma, and Rhode Island, stepped up their timeline in advance of the federal mandate to require compliance in January 2020. Others are following suit throughout 2020 and beyond.
For a full list of states that have e-prescribing mandates, check out “When is E-prescribing Mandatory for Psychiatrists?”
The regulations apply to any provider prescribing a controlled substance to a person eligible for Medicare Part D and any providers in a state with an EPCS mandate. In order to comply with EPCS regulations, all health providers who prescribe controlled substances, pharmacies, and benefits managers need to have the appropriate technology in place to fulfill the requirements. Depending on the EHR software you choose, implementation can be challenging and not something you want to wait until the last minute to do.
What are Your Responsibilities as a Psychiatrist?
Psychiatrists prescribing controlled substances are required to ensure the safety of EPCS per DEA Title 21, and this is done in a number of ways. They are required to obtain a DEA number to prescribe controlled substances. Providers must also implement a certified EHR software, enabling creating and transmitting electronic prescriptions that are compliant with state and federal mandates.
There are some additional safety and security measures as well. Providers must implement additional security procedures, including maintaining sole possession of any two-factor authentication tokens and cannot share their password. All providers prescribing controlled substances also must register with their state’s Prescription Drug Monitoring Program (PDMP). State requirements may vary, but it’s generally recommended to check the PDMP at least every three months and before prescribing any opiates for a patient.
Additional Safety Precautions
Given the EPCS regulation’s intent to reduce drug overdose deaths, it may be a good idea for you to consider some additional precautions when prescribing controlled substances. These are not required, though they are added safety measures that may have a positive impact.
Some things to consider are requiring regular appointments or check-ins to confirm the medication is still appropriate and that your patient is taking it as prescribed. You can also require refill requests a minimum of a few days before the medication will run out to provide time to respond to the request. Additionally, you’ll want a policy for how often you check your state’s PDMP to minimize the chance of abuse for any of your patients on controlled substances.
Last, consider creating a Controlled Substance Agreement for your patients to sign to ensure their understanding of the importance of taking the medication as prescribed. This agreement can help to open the dialogue about the risks of using controlled substances and potentially offer some liability protection for your practice.
What Are the Requirements for a Compliant EHR Software?
EHR software is required to be certified by a certification body or third-party auditor. As part of the process, the software must ensure that providers who prescribe controlled substances have a DEA registration number and they are the only person signing electronic prescriptions.
Certified EPCS systems must:
- Verify that a provider has authorization to prescribe controlled substances.
- Engage in two-factor authentication for providers who sign prescriptions for a controlled substance.
- Implement two-step logical access controls granting approved prescribers with EPCS permissions.
- Provide detailed reporting demonstrating compliance.
- Have the ability to audit for any breach of security incidents.
EPCS mandates provide a systematic way to reduce substance addiction and abuse by implementing increased oversight and careful monitoring of controlled substance prescriptions. It’s crucial to select an EHR certified for EPCS, offering the features and security measures required to safely prescribe controlled substances while following state and federal mandates.
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