EPCS Question

[docB]

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EPCS = Electronic Prescribing of Controlled Substances

As of 1/1/21 my state requires all controlled substance prescriptions to be sent to pharmacies electronically. It's a long story but it kinda came out of the blue last December. I'm one of the tech/compliance guys for my group so this was a nightmare. It's basically dealt with now and we can do EPCS through our EMR. For this year we can use a paper form stapled to a paper prescription waiving the EPCS requirement when we have a system downtime.

But we don't have a plan as to how we'll deal with downtimes next year. As of 1/1/22 no more paper waiver forms and all CS prescriptions must go electronically.

For those of you who have been dealing with this requirement for a while what do you do when the computers are down?

I know some of the options are:
Wait for the system to come back up and send the script then. Not great if that means you have to get up after a night shift and enter some scripts.
Don't write for controlled substances. Not great for patients with legit, painful issues.
Have another doc write the scripts once the system is back up. I know I don't like having my name on other doc's stuff.

I've been bugging people in my group and system IT about this but no one cares as it won't be a real issue until New Year's. And, as usual, they'd rather wait until it's a crisis at 2am on January 4th rather than fix it now when it's easy.

 

[bravotwozero]

Does your state give out waivers? Same law went into effect here in TX, but you can go on the medical board's website and apply for an e prescribing waiver, which gets approved as soon as you apply for it, and you can print out your profile that says the waiver is in effect. I give the patient that printout along with a paper narc Rx, when I need to. One of the FSEDs I work at still doesn't have e prescribing capability.

 

[Birdstrike]

EPCS = Electronic Prescribing of Controlled Substances

As of 1/1/21 my state requires all controlled substance prescriptions to be sent to pharmacies electronically. It's a long story but it kinda came out of the blue last December. I'm one of the tech/compliance guys for my group so this was a nightmare. It's basically dealt with now and we can do EPCS through our EMR. For this year we can use a paper form stapled to a paper prescription waiving the EPCS requirement when we have a system downtime.

But we don't have a plan as to how we'll deal with downtimes next year. As of 1/1/22 no more paper waiver forms and all CS prescriptions must go electronically.

For those of you who have been dealing with this requirement for a while what do you do when the computers are down?

I know some of the options are:
Wait for the system to come back up and send the script then. Not great if that means you have to get up after a night shift and enter some scripts.
Don't write for controlled substances. Not great for patients with legit, painful issues.
Have another doc write the scripts once the system is back up. I know I don't like having my name on other doc's stuff.

I've been bugging people in my group and system IT about this but no one cares as it won't be a real issue until New Year's. And, as usual, they'd rather wait until it's a crisis at 2am on January 4th rather than fix it now when it's easy.

In my state, they wrote into the law that an exception for a non-escribed controlled is if there's a computer outage and it's documented in the chart. If there is no workaround in case of outages, your state legislature either needs to amend the law, or on Jan 1, 2022 you can tell your patients, "Sorry, it's against the law for me to write you an Rx right now. Here's the number to complain to the governor and state reps. Call them."

There has to be a workaround in place for system outages which are a frequent reality of our daily work-life. My guess is the law will be amended before 12/31/2021.

 

[thegenius]

EPCS = Electronic Prescribing of Controlled Substances

As of 1/1/21 my state requires all controlled substance prescriptions to be sent to pharmacies electronically. It's a long story but it kinda came out of the blue last December. I'm one of the tech/compliance guys for my group so this was a nightmare. It's basically dealt with now and we can do EPCS through our EMR. For this year we can use a paper form stapled to a paper prescription waiving the EPCS requirement when we have a system downtime.

But we don't have a plan as to how we'll deal with downtimes next year. As of 1/1/22 no more paper waiver forms and all CS prescriptions must go electronically.

For those of you who have been dealing with this requirement for a while what do you do when the computers are down?

I know some of the options are:
Wait for the system to come back up and send the script then. Not great if that means you have to get up after a night shift and enter some scripts.
Don't write for controlled substances. Not great for patients with legit, painful issues.
Have another doc write the scripts once the system is back up. I know I don't like having my name on other doc's stuff.

I've been bugging people in my group and system IT about this but no one cares as it won't be a real issue until New Year's. And, as usual, they'd rather wait until it's a crisis at 2am on January 4th rather than fix it now when it's easy.

What state are you in?

In CA, I don't think it's law yet, but I'm sure it will be in due time. Right now it's highly encouraged to do all ePrescribing. 99.5% of the time the computers are operational there's probably a few hours a year where the internet or computer system are down.

I think the bigger problem is when patients say "Doc, the Walgreens on Main street where you sent the prescription to didn't get it. Can you sent it to CVS on First street? It's much closer to where I am."

And then they pick up two prescriptions.

As far as I know, once you send a prescription to a pharmacy from your EMR you can't cancel it. Well...you can cancel it in the EMR but I don't think it sends a cancel request to the pharmacy?

 

[gutonc]

What state are you in?

In CA, I don't think it's law yet, but I'm sure it will be in due time. Right now it's highly encouraged to do all ePrescribing. 99.5% of the time the computers are operational there's probably a few hours a year where the internet or computer system are down.

I think the bigger problem is when patients say "Doc, the Walgreens on Main street where you sent the prescription to didn't get it. Can you sent it to CVS on First street? It's much closer to where I am."

And then they pick up two prescriptions.

As far as I know, once you send a prescription to a pharmacy from your EMR you can't cancel it. Well...you can cancel it in the EMR but I don't think it sends a cancel request to the pharmacy?

Unless you're sending it to the hospital pharmacy or a pharmacy in your system, no, canceling it in the EMR (Epic at least) won't cancel it at the pharmacy. But what you can see (again, in Epic) is a time-stamped acknowledgement that the prescription was received by the pharmacy you sent it to, whatever pharmacy it was. So at least you can call BS on that one pretty easily.

 

[thegenius]

Unless you're sending it to the hospital pharmacy or a pharmacy in your system, no, canceling it in the EMR (Epic at least) won't cancel it at the pharmacy. But what you can see (again, in Epic) is a time-stamped acknowledgement that the prescription was received by the pharmacy you sent it to, whatever pharmacy it was. So at least you can call BS on that one pretty easily.

Yea i have to look into that...the timestamp that it was successfully sent to the pharmacy.

As you know...people will go to extraordinary lengths to get their oxycodone or lorazepam.

 

[southerndoc]

The latest version of Epic was supposed to include pharmacy notification of canceled prescriptions. I have not verified it. I can ask our Epic representative in our group if you want.

Nationally, CVS, Walmart, and one other pharmacy (Walgreens maybe?) will require all controlled substances to be e-prescribed. This was set to go into effect this year but was postponed because of COVID. There are issues with some pharmacies where a PA, NP, or resident e-prescribes a controlled substance, the "second signer" verifying the script (the physician) won't have his or her DEA number included in the prescription. This is just a statement and not intended to start a debate whether PA/NP's should prescribe controlled substances.

I think your best option is to have the physician who saw the patient during downtime to e-prescribe once the system is back up. He or she can even do this from home. However, some EMR's won't allow e-prescribing for a discharged patient. I can see where this can become very problematic. You shouldn't ask another doc to e-prescribe for a patient you saw as this may open him/her up to liability.

 

[BoardingDoc]

As far as I know, once you send a prescription to a pharmacy from your EMR you can't cancel it. Well...you can cancel it in the EMR but I don't think it sends a cancel request to the pharmacy?

Ours does. If I cancel an Rx that I've sent, it asks if I want to notify the pharmacy as well. Click yes, Rx vanishes from there.

 

[Birdstrike]

Ours does. If I cancel an Rx that I've sent, it asks if I want to notify the pharmacy as well. Click yes, Rx vanishes from there.

That's a good feature. With mine, if we cancel digitally, we then have to call the pharmacy to verbally cancel, then document a note in the EHR that it was canceled at the pharm.

 

[docB]

Thank you for all the replies. I really appreciate the help.

Does your state give out waivers? Same law went into effect here in TX, but you can go on the medical board's website and apply for an e prescribing waiver, which gets approved as soon as you apply for it, and you can print out your profile that says the waiver is in effect. I give the patient that printout along with a paper narc Rx, when I need to. One of the FSEDs I work at still doesn't have e prescribing capability.

We are allowed to use a waiver but only for this year. No waivers in 2022.

How all this happened in NV is a really long story. The very brief summary is that the legislature passed the law in 2017 to go into effect 1/1/21. The Board of Pharmacy thought they were going to be allowed to postpone it until 1/1/22 based on the pandemic and the governor's emergency declaration. They weren't ready to go and really wanted the delay. But in late December the state attorney decided that the mandate wasn't covered under the pandemic declaration. So every prescriber in the state got an email on 12/27/20 saying "Guess what?" Because the BOP was unprepared they created a waiver system that is super easy. You just print out the form from their website, sign it and staple it to the prescription. The board doesn't even want it. The actually told us to quit sending them into the board after they got hundreds in the first few weeks. The whole thing was such a mess some of the pharmacies were rejecting the waivers because they thought they were a joke.

In my state, they wrote into the law that an exception for a non-escribed controlled is if there's a computer outage and it's documented in the chart. If there is no workaround in case of outages, your state legislature either needs to amend the law, or on Jan 1, 2022 you can tell your patients, "Sorry, it's against the law for me to write you an Rx right now. Here's the number to complain to the governor and state reps. Call them."

There has to be a workaround in place for system outages which are a frequent reality of our daily work-life. My guess is the law will be amended before 12/31/2021.

I wish that were the case. Our legislature isn't very physician friendly any more. They refused to provide any amendments for the controlled substance law they passed that went into effect in 2018 which has a lot of onerous requirements. They're fighting the opioid crisis by making it almost impossible to prescribe controlled substances. That way they can claim to be doing something and the numbers are going down but the patients take out their frustrations on the doctors, not the politicians.

As for telling the patients whose fault it is I've been jousting that windmill for a while. I wrote the controlled substance discharge instruction that's used by the system:

"Nevada Senate Bill 459 and Assembly Bill 474
The Nevada Legislature passed Senate Bill 459 which demands that any patient who receives a prescription for a controlled substance, such as narcotic pain medicine or many anxiety medicines and sleeping pills, MUST have their information checked in the State of Nevada Prescription Monitoring Program database. This database tracks all prescriptions filled for controlled medications. The Nevada State Legislature has created this requirement to fight drug abuse and prescription fraud.

If you have been given a prescription for a controlled substance your prescription history with the state database has been evaluated.

If you have been denied a prescription for a controlled substance this may have been because your prescription monitoring profile shows a concerning pattern such as many pills obtained recently, many prescriptions filled, different medications obtained or multiple different prescribers providing prescriptions.

The Nevada Legislature has also passed Assembly Bill 474 which sets many requirements for the prescription of a controlled substance. To be prescribed a controlled substance you must have a risk assessment performed, be informed of the risks of controlled substances and other issues such as proper storage and disposal and many other issues. You must sign a statement of informed consent to being treated with a controlled substance. Your prescriptions must be prepared to include special information required by law.

Meeting all of these requirements takes time and may have delayed your discharge.

Thank you for your understanding about delays from these legal requirements.

If you have concerns or complaints about this process please feel free to call your Nevada State Senator or Assemblyman. You can determine who your state legislators are by going to leg.state.nv.us or by calling 702-486-2626."

What state are you in?

In CA, I don't think it's law yet, but I'm sure it will be in due time. Right now it's highly encouraged to do all ePrescribing. 99.5% of the time the computers are operational there's probably a few hours a year where the internet or computer system are down.

I think the bigger problem is when patients say "Doc, the Walgreens on Main street where you sent the prescription to didn't get it. Can you sent it to CVS on First street? It's much closer to where I am."

And then they pick up two prescriptions.

As far as I know, once you send a prescription to a pharmacy from your EMR you can't cancel it. Well...you can cancel it in the EMR but I don't think it sends a cancel request to the pharmacy?

We've been dealing with this by calling the initial pharmacy and cancelling the first prescription. The whole process is really difficult and time consuming.

 

[Birdstrike]

... I wrote the controlled substance discharge instruction that's used by the system:

"Nevada Senate Bill 459 and Assembly Bill 474...

If you have concerns or complaints about this process please feel free to call your Nevada State Senator or Assemblyman. You can determine who your state legislators are by going to leg.state.nv.us or by calling 702-486-2626."


We've been dealing with this by calling the initial pharmacy and cancelling the first prescription. The whole process is really difficult and time consuming.

Excellent.