Electronic Prescribing of Controlled Substances (EPCS)

Find EPCS software products and pricing, rule regulations and waiver exemption information. 

What is Electronic Prescribing?

Electronic prescribing also known as “e-Prescribing” or “eRx” is the ability for health care providers to enter prescription information into a computer device (such as a tablet, laptop, or desktop computer) and securely transmit the prescription to pharmacies using a special software program and connectivity to a transmission network. When a pharmacy receives a request, it can begin filling the medication right away.

The Benefits of e-Prescribing:
  • Help improve health care quality and patient safety by reducing medication errors and checking for drug interactions.
  • Make care more convenient by allowing providers to electronically request prescription refills.

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 and when ordering each EPCS. Authentication involves the physician providing a PIN number, an iris scan or thumb print, or using a device or card. Physicians can delegate EPCS or EPCS renewals 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?

Starting 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 requirement coincides with Medicare’s electronic prescription requirement which also begins on Jan. 1, 2021.

The Medicare eRx requirement is specific to any prescription 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.

As an additional reminder that 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 will need to have the ability to e-prescribe controlled substances either through their EHR or via a standalone eRx product. To e-prescribe through an EHR platform physicians must check with their EHR vendor to ensure the functionality is activated (this may require an added cost to activate). Additionally, EPCS is typically a separate function from traditional e-prescribing therefore physicians must request that this be an added feature as well, which will most likely be another added cost. 

If you do not have an EHR, your EHR does not have eRx and/or EPCS functionality, or the cost of adding the functionality to your current EHR is too expensive, physicians can purchase standalone eRx products that work independent of your EHR/practice management system. Find standalone eRx software products by browsing Surescripts certified provider software, be sure to focus your search “Standalone eRx”. This search function also identifies which software has EPCS capabilities. 

You may also choose to focus your search by EPCS capability which will list all products with the ability to prescribe controlled substances (both EHR and standalone software).
The following is pricing information for the standalone eRx products identified in the Surescripts search tool:
  • Allscripts ePrescribe – Starts at $33 /month with EPCS.
  • DAW Systems ScriptSure – Users can purchase the software as a monthly license or annual license, additional fees apply for use of EPCS. Contact directly for price information.
  • DrFirst iPrescribe – Free for one year and will continue to be free if providers write 20 or more prescriptions a month. If less than 20 prescriptions are written, they will be charged $20/month.
  • DrFirst Rcopia – $799/year per prescriber (with EPCS) + $75 one-time set-up fee per prescriber. Fees for additional optional services include patient demographic import ($525) and custom training session ($149).
  • eazyScripts – $79.95/month or $799.95/year, EPCS included at no extra cost. No additional set up or cancellation fees included. Use code ONBOARD20 for 20% off. 
  • OnCallData – $600/year per provider, for EPCS, providers must be identity-proofed and have a private security certificate on a token issued by a third-party. Fees for additional optional services include one-time patient demographic import ($200) and Integration with practice management system or EMR for continuous patient demographic updates ($500).
  • MD Toolbox-Rx – $38/month or $420/year with EPCS (free 30-day trial).
  • RxNT eRx – $650/year + $75 fee for EPCS
Find reviews on some of these products here

Are There Exemptions?

Both the Texas law (HB 2174) and the national Medicare mandate provide possible exemptions to their requirements via a prescriber waiver, which requires an application and can be renewed annually (each waiver is only valid for one year). To be eligible for a waiver a physician must demonstrate:  
  • economic hardship;
  • technological limitations not reasonably within the control of the prescriber; or
  • other exceptional circumstances demonstrated by the prescriber. 
Texas law also states a prescription for a controlled substance is not required to be issued electronically and may be issued in writing (without a waiver) if the prescription is issued:
  • by a veterinarian;
  • in circumstances in which electronic prescribing is not available due to temporary technological or electronic failure, as prescribed by board rule;
  • by a practitioner to be dispensed by a pharmacy located outside this state, as prescribed by board rule;
  • when the prescriber and dispenser are in the same location or under the same license;
  • in circumstances in which necessary elements are not supported by the most recently implemented national data standard that facilitates electronic prescribing;
  • for a drug for which the United States Food and Drug Administration requires additional information in the prescription that is not possible with electronic prescribing;
  • for a non-patient-specific prescription pursuant to a standing order, approved protocol for drug therapy, collaborative drug management, or comprehensive medication management, in response to a public health emergency or in other circumstances in which the practitioner may issue a non-patient-specific prescription;
  • for a drug under a research protocol; and
  • under circumstances in which the practitioner has the present ability to submit an electronic prescription but reasonably determines that it would be impractical for the patient to obtain the drugs prescribed under the electronic prescription in a timely manner and that a delay would adversely impact the patient’s medical condition.
Additional Medicare exemptions (not requiring a waiver) are as follows:
  • a prescription issued when the practitioner and dispensing pharmacy are the same entity;
  • a prescription issued that cannot be transmitted electronically under the most recently implemented version of the National Council for Prescription Drug Programs SCRIPT Standard;
  • a prescription issued by a practitioner under circumstances in which, notwithstanding the practitioner’s ability to submit a prescription electronically as required by this subsection, such practitioner reasonably determines that it would be impractical for the individual involved to obtain substances prescribed by electronic prescription in a timely manner, and such delay would adversely impact the individual’s medical condition involved;
  • a prescription issued by a practitioner prescribing a drug under a research protocol;
  • a prescription issued by a practitioner for a drug for which the Food and Drug Administration requires a prescription to contain elements that are not able to be included in electronic prescribing, such as a drug with risk evaluation and mitigation strategies that include elements to assure safe use;
  • a prescription issued by a practitioner — ‘‘(I) for an individual who receives hospice care under this title; and ‘‘(II) that is not covered under the hospice benefit under this title; and
  • a prescription issued by a practitioner for an individual who is — ‘‘(I) a resident of a nursing facility; and ‘‘(II) dually eligible for benefits under this title and title XIX.
A pharmacist who receives a controlled substance prescription in a manner other than electronically is not required to verify that the prescription is exempt from the requirement of electronic submission. The pharmacist may dispense a controlled substance pursuant to an otherwise valid written, oral, or telephonically communicated prescription. 

How Can I Apply for An Exemption Waiver?

For both the Texas and national Medicare e-prescribing requirements, the rules and waiver process has not yet been established. The Texas State Board of Pharmacy and regulatory entities for prescribers will jointly develop rules to implement the law, and each regulatory entity will enforce the law and issue waivers for the agency’s licensees.

It is not clear if physicians will need to apply for waivers for both requirements or just one overarching waiver. Once these rules are established HCMS will provide additional information. 

Where Can I Find More Information?

You can find more information on electronic prescribing at the Texas Medical Association’s online prescribing resource center