October 3, 2014
Mandatory Electronic Prescribing Effective March 27, 2015
This is the headline that jumps off of the page on the New York Bureau of Narcotic Enforcement’s (BNE) website, and March 27 is the drop-dead date, no ifs ands or buts. March 27 is only 169 days away, and all physicians, with few exceptions, must go paperless for both legend and controlled substances.
Ever since the BNE adopted state regulations for mandatory electronic prescribing back in early 2014, prescribers have questioned whether or not they need to comply.
Let us assure you, from all our discussions with customers and providers, that all New York practitioners are required to comply with the law and begin electronically sending all prescriptions.
Time’s running out, so if you are not electronically prescribing, now is the time to find a solution that will enable you to e-prescribe both legend and controlled substances. If you don’t have controlled substance e-prescription capability, we suggest you contact your point-of-care vendor (EHR, EMR, eRx company) as soon as possible to find out their plans for supporting all of your electronic prescribing needs.
If your point-of-care vendor doesn’t offer electronic prescribing of controlled substances (EPCS), and many don’t, you should evaluate vendors that do offer EPCS functionality. Surescripts has a list of approved vendors for EPCS as well as legend substances. Of course, DrFirst offers legend drug e-prescribing through its Rcopia® platform and EPCS e-prescribing through its EPCS GoldSM 2.0 software and we encourage you to consider this companion solution.
You may be wondering why so few vendors support both legend drug and controlled substance e-prescribing; it is incredibly challenging to develop a solution that meets the DEA’s requirements for EPCS. Not all vendors are able to meet this bar along with all the other competing priorities such as adding the features needed for Meaningful Use.
Once you’ve gone through the necessary steps to confirm that your current point-of-care vendor has EPCS functionality, found a new vendor, or for some, go paperless for the first time, you will need to complete the following:
- Go through the identify proofing process
- Receive your two-factor authentication
- Gain “access” to use your EHR or e-prescribing solution for EPCS (this is a specific process required by the DEA
- Contact the BNE and send them the paperwork
- Send a prescription for a controlled drug to an EPCS-enabled pharmacy
Per the I-STOP regulation, all prescriptions must be electronically sent beginning March 27, but if you have a solution now, begin sending all your prescriptions electronically so it becomes a habit, and keep in mind:
- Check the PMP before you prescribe
- EPCS prescriptions may only be processed for one patient at a time, per the DEA rules
- Faxed prescriptions will be invalid after March 27
- You may keep paper prescriptions in your office for out of state prescriptions or in the case of a network failure (NY state paper prescriptions are limited to a 5-day supply after March 27)
ONE LAST POINT: Time is of the essence, remember that this is a process.
Look for our next blog where we’ll provide more detail on the provider process and requirements for EPCS in NY.