Transcript What is EPCS?

Electronic Prescribing of Controlled Substances:
Prescriber and Agent Workflow
Part 3 of a 3 Part Series
Chuck Klein, Ph.D.
GM/Director, Medication Management
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Agenda
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Defining EPCS
Requirements: Prescribers
Workflow for Prescribers
Workflow for Agents
OrderConnect Timeline
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What is EPCS?
• EPCS—the Electronic Prescribing of Controlled Substances—
allows prescribers who use an EPCS-certified e-prescribing
application to send prescriptions for controlled substances
electronically to pharmacies.
• Although highly desired, EPCS is not mandatory, except for New
York State prescribers (effective 3/27/2015).
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What is Required for Prescribers
to do EPCS?
Prescribers:
• The DEA requires prescribers to go through Identity Proofing
and Issuance of Credentials.
• Specific processes are outlined by the DEA for ‘activating’
physicians to do EPCS.
• Two factor authentication is required by prescribers when
transmitting EPCS prescriptions.
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Workflow for Prescribers
In general, the workflow for prescribers will be the same across the
board with a few exceptions:
• Montana and Missouri: Prescribers cannot electronically
prescribe any controlled substances
• Kansas and Vermont: Prescribers cannot electronically
prescribe Schedule II controlled substances
• Texas: Nurse practitioners cannot electronically prescribe
Schedule II controlled substances (physicians can)
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Choosing and Creating the Prescription
For scheduled medications, a new field—required by the DEA—
has been added called “Earliest Fill Date.”
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Earliest Fill Date for C-II Medications
13 CFR 1306.12
• The authorization of refills of C-II medications is not allowed.
• However, a prescriber may issue multiple prescriptions authorizing the
patient to receive a total of up to a 90-day supply of a C-II medication
provided the prescriber provides written instructions on each
prescription (other than the first one if the prescriber intends it to be
filled immediately) indicating the earliest date on which a pharmacy
may fill each prescription.
• OrderConnect will do the math with regards to issuing no more than 90
days of the medication and calculating earliest fill dates (eg, end date
minus 5 days).
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Earliest Fill Date for C-III&IV Medications
13 CFR 1306.22
• No prescription for a Schedule III or IV controlled substance shall be
filled or refilled more than six months after the date on which such
prescription was issued.
• No prescription for a controlled substance listed in Schedule III or IV
authorized to be refilled may be refilled more than five times.
• OrderConnect will do the math with regards to issuing no more than six
months of the medication and its refills and calculating earliest fill dates
as needed (eg, end date minus 5 days).
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Special Case Prescriptions
If a prescription is written for Subutex, Suboxone, Zubsolv or their generic
equivalents, the prescriber’s Narcotics Addiction DEA Number (NADEAN)
must appear on the prescription. If the prescriber does not have a
NEDEAN in his OrderConnect profile, he will not be able to prescribe those
medications electronically. (21 CFR 1306.05(b))
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Special Case Prescriptions
If a prescription is written for Xyrem (aka, gamma-Hydroxybutyric acid;
GHB), the prescriber must indicate on the prescription the medical need of
the client for the prescription. (21 CFR 1306.05(c))
When a prescription for Xyrem is written, OrderConnect will automatically
insert a text box where the prescriber will be required to enter the medical
need of the medication. If it is not populated the prescription will not
advance through the prescribing process.
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Prescriber Reminders
OrderConnect will gently remind prescribers of the DEA rules if they forget
them.
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Order Confirmation: Multiple DEA Numbers
If a prescriber has more than one DEA number listed he/she will be able to
choose the one they want to associate with the prescription via the
dropdown.
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Order Confirmation: Individual Rx Options
Each individual prescription will now have it’s own output options, including
pharmacy selection.
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Order Confirmation: Controlled
Substances—”Ready to Sign”
For EPCS-enabled prescribers, each prescription for a controlled
substance must be checked off as “Ready to Sign” before proceeding with
output. CFR 1311.120b(10)
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Order Confirmation: Controlled
Substances—Signing
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A DEA required message will appear on the Order Confirmation screen
when you are working with controlled substances:
“By completing the two-factor authentication protocol at this time,
you are legally signing the prescription(s) and authorizing the
transmission of the above information to the pharmacy for
dispensing. The two-factor authentication protocol may only be
completed by the practitioner whose name and DEA registration
number appear above.”
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Order Confirmation: Controlled
Substances—Signing
Upon clicking the “Sign” button the prescriber will be required to input her
credential for authentication.
The credential will original from
the prescriber’s hard or soft
token. After entering the
credential the prescription will
be sent electronically to the
pharmacy chosen.
The prescriber only has to enter
the credential once and it will
apply to all of the controlled
substance prescriptions.
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Special Cases
• If a prescription for a controlled substance was successfully sent
electronically, it cannot be printed or resent.
• If a prescription for a controlled substance was sent
electronically and failed, it can be printed and will contain the
following information on it:
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The fact that the prescription was originally intended to be sent
electronically
The name of the specific pharmacy to which the transmission
failed
Complete date/time stamp of the failed attempt
The fact that the transmission failed
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Special Cases
• If a prescription for a controlled substance was successfully
printed it cannot be sent electronically.
• If a ‘chart copy’ of a prescription for a controlled substance is
printed, it will clearly indicate that it is not a valid prescription.
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Prescriber Agent Workflow
The Agent will follow the same workflow as the prescriber. The main
change is on the Order Confirmation screen. As usual, the Agent will
choose the name of the prescriber for whom she is generating the verbal
Order (and can see the DEA number of the prescriber).
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Prescriber Agent Workflow for VOs
The Agent will not be able to choose any output; all output options will be
unavailable. Also, the word “Pending” will appear. The Agent will then click
the Accept button, as usual.
After clicking the Accept
button, a DEA-mandated
message will appear.
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Prescriber Agent Workflow for VOs
The medication will show up on the Current Medication Profile screen and
will be highlighted in yellow and say “Pending” next to it until the prescriber
authenticates it and transmits it.
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Prescriber VO Queue for Verbal Orders
A new Prescriber VO Queue will be available on the Prescribers Desktop screen,
located in the same place as the current Refill Request Queue. All verbal orders for
controlled substances will go into the queue. The prescriber will be required to
indicate “Ready to Sign” each prescription that she approves and then authenticate
and transmit per the workflow previously prescribed.
An indicator will also appear in client records indicating if the prescriber has any
VOs for any clients in her queue.
The Prescriber VO Queue is currently under construction.
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OrderConnect’s Timeline for EPCS
• OrderConnect EPCS will be released for use by our New York
clients on March 16, 2015.
• Prior to its release, user documentation will be provided as well
as a recorded training webinar.
• Instructions will also be sent that will allow providers to go
through identity proofing and credentialing.
• In addition, information will be sent to our NY clients that will
allow them to register their OrderConnect with the NY Bureau of
Narcotic Enforcement.
• OrderConnect EPCS will be available for use by all other clients
by April 30, 2015.
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What Will the Additional Cost be
for EPCS?
• EPCS Setup for Use with a Soft Token (per prescriber): $40.00 (onetime fee)
• EPCS Setup for Use with a Hard Token (per prescriber): $50.00 (onetime fee)
• EPCS Setup for Use with both a Hard Token and Soft Token (per
prescriber): $75.00 (one-time fee)
• EPCS Monthly Subscription Fee (per prescriber-in addition to their
OrderConnect subscription fee): $8.00 per month (billed annually)
• If a prescriber fails online Identity Proofing and is required to complete a
notarized form, an additional $50 fee will be charged.
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Questions?
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