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2015 User Conference
Electronic Prescribing of Controlled Substances (EPCS) April 25, 2015
Presented by:
Peter MinioProduct Manager, Pediatric and Primary Care SolutionsRoom Monitor:
Jeanette JonesServices Support
EHR Session
2015 Office Practicum User Conference
Learning Objectives
● Background information about EPCS and I-STOP.
● Readiness for EPCS.● Identity-Proofing (IDP).● How OP has implemented EPCS.
2015 Office Practicum User Conference
Background
• The Controlled Substances Act of 1970 mandated a high level of governance over controlled substances in order to prevent illegal uses.
• ePrescribing controlled substances (Schedule II-V) was made legal by the DEA in 2010.○ Adopted to further reduce fraud and
abuse.○ Stringent requirements to address
concerns in an electronic environment.○ Not mandated on the federal level.○ States have right to further regulate.
2015 Office Practicum User Conference
Benefits of EPCS
• Reduce fraud and abuse.• Improve patient safety.• Single workflow for all medications with
more efficient record keeping.• Reduce the cost of regulatory compliance.• Be audit-ready.
2015 Office Practicum User Conference
Readiness
• Software providers (e.g., OP) must implement the capabilities, but also complete both a certification and a third-party audit.
• Many EHR vendors and pharmacies are not ready.○ As a result, provider adoption is low.
2015 Office Practicum User Conference
State Readiness
● Currently 48 states and the District of Columbia allow ePrescribing.○ Missouri and Montana
do not permit EPCS.○ Vermont does not
permit Schedule II drugs to be transmitted electronically.
● More than 70% of pharmacies nationally are certified for EPCS.
2015 Office Practicum User Conference
I-STOP - New York
● Mandates ePrescribing for both legend drugs (any drug that requires a prescription) and controlled substances by March 27, 2015.o On March 13, 2015 Governor Cuomo signed into law a
bill which delays implementation until 2016.● Requires providers check the Prescription
Monitoring Program (PMP) and obtain a confirmation number before prescribing a controlled substance.
● On March 13, 2015 Governor Cuomo signed into law a bill which delays implementation until 2016.
2015 Office Practicum User Conference
Prescriber Requirements
●Prescribers must go through a form of electronic authentication, otherwise known as identity-proofing (IDP).●Each provider must be issued “two-factor authentication” credentials. ○ Two-factor authentication is when a user
provides two forms of identification (something they know and something on them):■ Password.■ Hard or soft token.■ Biometric (fingerprint scan).■ Example: ATM card and PIN number.
●Credentials to each user are granted access with logical access controls.
2015 Office Practicum User Conference
What is OP Doing About EPCS?
● Office Practicum has partnered with DrFirst to deliver EPCS functionality.○ DrFirst uses Experian (a major credit
reporting bureau) for IDP.● Each provider will need to complete an IDP
process through Experian.● On March 13, 2015 Governor Cuomo signed
into law a bill which delays implementation until 2016.○ Additional charges apply.
2015 Office Practicum User Conference
IDP Process
• Sign an add-on agreement and provide necessary additional information:o Unique email address per provider.o DEA#, NPI, Address
• A hard token will be issued to each provider.o You may also download a soft token.
Important Note: Per DEA regulations, soft tokens must be utilized from a different
device than the device prescribed from.
• IDP is a 7 Step process performed online.o Must provide personal information
such as Social Security Number, DOB.o Must answer 3-4 questions pertaining to
personal financial history.
2015 Office Practicum User Conference
Step 7 of IDP
● Once Step 6 is completed, Experian will send a confirmation code to the provider’s home address.
● The provider must log back into the IDP system and enter the confirmation code in order to complete Step 7.
2015 Office Practicum User Conference
Logical Access Control (LAC)
● LAC will be available from within OP for administrative users only.
● Used to make a provider that has completed the IDP process either active or inactive.
2015 Office Practicum User Conference
Provider Dashboard
● A dashboard will be available from OP where providers may enable/disable hard/soft tokens and biometric devices.
● Prescribers are allowed to have more than one device associated with their identity.
2015 Office Practicum User Conference
New Rules
● A controlled substance:○ Can only be sent electronically to a
pharmacy or printed for dispensing once.■ Exception: If the transmission failed.
○ If printed after being sent or previously printed, it will be marked as a copy and instruct the pharmacist not to dispense.
● Once a controlled substance is sent or printed, it cannot be edited.
2015 Office Practicum User Conference
NADEAN
● Certain drugs require a Narcotics Addiction DEA (NADEAN) Number (e.g., Suboxone) to be included in the pharmacist notes.
2015 Office Practicum User Conference
HGB
● Drugs that contain gamma-Hydroxyburtric acid (e.g., Xyrem) must contain a reason for prescribing in the pharmacist notes.
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