eScript for CII?

[SClENCE]

Is this legal? I always though not and have never seen a doctor send one but we got one last week. This is what I have gathered as far as the laws for my state -
______________________________________________________

Prescriptions for schedule II controlled substances may not be transmitted by facsimile except for:

• A resident of a long term care facility pursuant to rule 4729-17-09 of the Administrative Code.
• A narcotic substance issued for a patient enrolled in a hospice. The original prescription must indicate that the patient is a hospice patient. The facsimile transmission must also meet the other requirements of this rule.
• A compounded sterile product prescription for a narcotic substance pursuant to rule 4729-19-02 of the Administrative Code.

A prescription may be transmitted by means of a board approved electronic prescription transmission system provided that:

• The system requires positive identification of the prescriber as defined in rule 4729-5-01 of the Administrative Code and the full name of any authorized agent of the prescriber who transmits the prescription.
• The computer data is retained for a period of three years at the prescriber's office.
• An electronic prescription transmission system meeting the requirements of 21 C.F.R. 1311for both controlled substance and non-controlled substance prescriptions shall be considered approved by the state board of pharmacy.

______________________________________________________

So facsimile transmission refers to faxes, not eScribes from my understanding. From what I can tell they can't fax a CII unless the patient is in hospice, long term care, or it is a sterile compound BUT they can eScribe with without any limitation? This doesn't seem correct and I have been told otherwise but I can't find anything stating that it is not in fact legal.

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[zelman]

Is this legal? I always though not and have never seen a doctor send one but we got one today. This is what I have gathered as far as the laws for my state -

Prescriptions for schedule II controlled substances may not be transmitted by facsimile except for:

• A resident of a long term care facility pursuant to rule 4729-17-09 of the Administrative Code.
• A narcotic substance issued for a patient enrolled in a hospice. The original prescription must indicate that the patient is a hospice patient. The facsimile transmission must also meet the other requirements of this rule.
• A compounded sterile product prescription for a narcotic substance pursuant to rule 4729-19-02 of the Administrative Code.

A prescription may be transmitted by means of a board approved electronic prescription transmission system provided that:

• The system requires positive identification of the prescriber as defined in rule 4729-5-01 of the Administrative Code and the full name of any authorized agent of the prescriber who transmits the prescription.
• The computer data is retained for a period of three years at the prescriber's office.
• An electronic prescription transmission system meeting the requirements of 21 C.F.R. 1311for both controlled substance and non-controlled substance prescriptions shall be considered approved by the state board of pharmacy.

So what I can tell they can't fax a CII unless the patient is in hospice, long term care, or it is a CII that is a sterile compound BUT they can eScribe with without any of these limitations?

I don't know Ohio law, but it's similar to your summary in Massachusetts.

 

[SClENCE]

I don't know Ohio law, but it's similar to your summary in Massachusetts.

So do you guys fill them or not? The PIC says it's illegal and turns them down (which I have no problem with) but the law only states that a fax is illegal.

 

[Dr Wario]

This is correct, escripts for CII's have a lot of security requirements (and thus not all doctors are able to send them due to software limitations). We are lucky that as of now the pill mills in our area have not started sending this way, but if they do they will learn very fast to cease.

 

[zelman]

So do you guys fill them or not? The PIC says it's illegal and turns them down (which I have no problem with) but the law only states that a fax is illegal.

Fill 100%. They are the only Rx's that I KNOW aren't altered/fake.

 

[SClENCE]

Fill 100%. They are the only Rx's that I KNOW aren't altered/fake.

If it's legal I actually would like this better. Probably less pre-dated scripts and defiantly less narc waiters in the store throughout the day.

I guess my next question is can a CII eScribe be transferred? I'm thinking that one of these would be literally impossible to get rid of if you were not comfortable filling it.

 

[radio frequency]

You need to read the DEA's Guide for Pharmacists. It answers all of these questions and more! While it's dry, it's pretty helpful.

http://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_manual.pdf

 

[Lnsean]

They're legal with the exception of a few states.

 

[WVUPharm2007]

Hopefully soon they will all be electronic.

 

[Corpseman]

Yep, we take them all the time here in AZ. I like them a lot better since the chance of losing the hard copy is pretty non-existent.

 

[Estrace]

They are legal in Texas and we have been getting them since last year. Not all doctors office are set up to send them but I like them better. No hard copy to sign or file.

 

[owlegrad]

Yup, legal in FL and I love it.

 

[WVUPharm2007]

Sooner or later, some physician is going to have his or her password for their prescription service social engineered out and eRxs for #480 Oxycodone 30s will flood the town.

"You mean I shouldn't use my wife's first name as my password?!?!"

 

[SClENCE]

Sooner or later, some physician is going to have his or her password for their prescription service social engineered out and eRxs for #480 Oxycodone 30s will flood the town.

"You mean I shouldn't use my wife's first name as my password?!?!"

Well if the Chinese can hack government files on a weekly basis this wouldn't surprise me.

 

[Son_Goku]

You need to read the DEA's Guide for Pharmacists. It answers all of these questions and more! While it's dry, it's pretty helpful.

http://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_manual.pdf

This is the latest? I'm assuming nothing has changed since 2010.

 

[maria1oh]

The only thing I don't like about the escripts is that I can't give the hardcopy back if we are out of stock.

 

[Old Timer]

They are legal and Mikey, while nothing is 100% safe, there is dual factor authentication that makes it more difficult for anyone except the prescriber to send them.

 

[radio frequency]

This is the latest? I'm assuming nothing has changed since 2010.

It's a loose outline of the Controlled Substances Act, which doesn't go through big changes often. Yes, it's the latest.

 

[MountainPharmD]

I like e-scripts. My computer system auto populates all the info right on the screen. If all doctors used e-scripts I could reduce my technician hours by one full time equivalent. However there are some issues. I see more mistakes on e-scripts than I even did on hand written scripts. The doctor picks the wrong drug from the drop down box, dispense quantity does not match the sig, or the sig is wrong.

There are many advantages to e-scripts, however I see many problems. One of the biggest problems is how easy it is for a prescriber to give their staff the e-script password. I have a clinic here in town and the nurses have told me they are the ones who send the e-scripts. The doctor charts what he wants to prescriber and they fill out and send the e-script. This clinic does not e-prescribe controls. Maybe on the systems that do allow e-prescribing of controls the doc needs a password and their finger print. I don't know.

 

[Old Timer]

I like e-scripts. My computer system auto populates all the info right on the screen. If all doctors used e-scripts I could reduce my technician hours by one full time equivalent. However there are some issues. I see more mistakes on e-scripts than I even did on hand written scripts. The doctor picks the wrong drug from the drop down box, dispense quantity does not match the sig, or the sig is wrong.

There are many advantages to e-scripts, however I see many problems. One of the biggest problems is how easy it is for a prescriber to give their staff the e-script password. I have a clinic here in town and the nurses have told me they are the ones who send the e-scripts. The doctor charts what he wants to prescriber and they fill out and send the e-script. This clinic does not e-prescribe controls. Maybe on the systems that do allow e-prescribing of controls the doc needs a password and their finger print. I don't know.

There are strict rules and any software that sends C-II's must pas testing and be approved by the DEA. There is not a single password that the doctor can give to hist staff to send the rx for C-II's

 

[BenJammin]

100% refusal? What the hell? At our outpatient pharmacy, we can't even receive electronic C2s sent by docs without the approved software.

 

[radio frequency]

If it's legal I actually would like this better. Probably less pre-dated scripts and defiantly less narc waiters in the store throughout the day.

I guess my next question is can a CII eScribe be transferred? I'm thinking that one of these would be literally impossible to get rid of if you were not comfortable filling it.

And no, a CII eScribe can't be transferred...just like a regular CII. If you can't fill it, you'd have to call the doctor and tell them, void the script, and the doc would have to write a new one to send elsewhere.

 

[SClENCE]

My doctor, who is an old timer, literally hired someone to follow him around and operate all of the electronics for him because he simply can't do it. There's no doubt she is sending eScripts lol. Every time I'm there he's complaining about computers.

 

[MountainPharmD]

My doctor, who is an old timer, literally hired someone to follow him around and operate all of the electronics for him because he simply can't do it. There's no doubt she is sending eScripts lol. Every time I'm there he's complaining about computers.

Do you live in Texas? We have a doc that does the same thing. He has an assistant whose only job is to follow him around with the laptop and send all his escripts.

 

[zelman]

Sooner or later, some physician is going to have his or her password for their prescription service social engineered out and eRxs for #480 Oxycodone 30s will flood the town.

"You mean I shouldn't use my wife's first name as my password?!?!"

As Old Timer said...

Q. What two-factor credentials will be acceptable?

A. Under the interim final rule, DEA is allowing the use of two of the following – something you know (a knowledge factor), something you have (a hard token stored separately from the computer being accessed), and something you are (biometric information). The hard token, if used, must be a cryptographic device or a one-time-password device that meets Federal Information Processing Standard 140-2 Security Level 1.