What is Electronic Prescribing?
Electronic prescribing, also known as “e-Prescribing” or “eRx”, is the process of electronically generating and sending a prescription order, so that physicians and other medical practitioners can transmit an electronic prescription to a pharmacy directly from the point of care using a special software program and connectivity to a transmission network.
What is e-Prescribing of Controlled Substances?
Electronic prescription of controlled substances or EPCS is a more secure form of prescription delivery and can help reduce controlled substance abuse caused by stolen prescription forms. EPCS differs from regular e-prescribing in that a physician must undergo an authentication process before using the technology. Authentication can involve the use of a PIN number, an iris scan or thumb print, or a device or card. Physicians can delegate EPCS to other clinical staff to complete all of the required information and then review, sign, and authorize the transmission of the prescription themselves.
What Am I Required to Do?
Texas state law e-prescribing requirements went into effect on Jan. 1, 2021. HB 2174
requires electronic prescribing of all controlled substances (CII–CV) by all Texas physicians, unless a waiver is granted. The Medicare eRx requirement is specific to any pr
escription for a covered part D drug under a prescription drug plan (or under a Medicare Advantage –PD plan) for a schedule II, III, IV, or V controlled substance
. More information can be found in the FAQs in this TMA resource
Summary - E-Prescribing for Controlled Substance Mandates
Medicare did not delay the mandate, just signaled its compliance would not be enforced until Jan. 1, 2022. If a physician successfully applies for a Texas waiver, it should be good for Medicare until Jan 1, 2022 after which a waiver would also need to be requested from Medicare.
- Texas did not delay the mandate for controlled substances to be filed electronically beginning Jan. 1, 2020. However, physicians who demonstrate financial or technical hardships, or other exceptional circumstances, can apply for a waiver that, if approved, will grant a one-year delay from the date of the waiver. There also are several exceptions to the e-prescribing mandate that do not require a waiver, including a temporary technological or electronic failure, certain emergencies, or when a physician or physician’s delegate issues a prescription to be dispensed by an out-of-state pharmacy. Please review the TMB waiver information below.
- HCMS is aware that hospitals are forwarding costs sent to them from the EHR vendor for adding e-prescribing capabilities for controlled substances to physicians. See below for other options with free-standing e-prescribing vendors that may provide a less costly option.
As an additional reminder, beginning on March 1, 2020, prescribers and pharmacists are required to check the patient's Prescription Monitoring Program (PMP) history prior to issuing or dispensing a new or refill prescription for an opioid, benzodiazepine, barbiturate, or carisoprodol. For more information on this requirement please visit the Texas PMP website
How Do I Meet These Requirements?
Physicians may have the ability to e-prescribe controlled substances through their EHR. EPCS is typically a separate function from traditional e-prescribing therefore physicians must request that this be an added feature, that may require an additional cost.
If this is not an available function in the EHR, or the cost is prohibitive, stand-alone eRx solutions are available that work independently of the EHR/practice management system. Find stand-alone eRx software products below and search for EPCS products.