Ten months might seem like a long time, but in healthcare, it can – and will – go by in the blink of an eye, especially when it comes to something as complex as the impending EPCS deadline. By January of 2021, essentially all healthcare organizations must have a solution in place for electronic prescribing of controlled substances. For a growing number of states, mandates are already in place.
The problem is that many leaders believe they’re prepared to meet the deadline, when it reality, most still have a long way to go.
“If you’re already live on e-prescribing and you think it’s going to be a no-brainer to hop over to EPCS, you may be caught off guard,” said Robin Lang, CIO at CaroMont Health, who addressed the topic in a recent webinar along with Phillip Coule, MD, Chief Medical Officer at Augusta University Health System, and Dan Borgasano, VP of Product Marketing with Imprivata. The event – Readying Your Organization for the Impending EPCS Deadline – provided an overview of the DEA requirements, addressed the key barriers facing CIOs and other leaders, and offered solutions to help ease the process.
The Why and the What
Although there are myriad reasons for enabling providers to prescribe electronically, the primary driver for the DEA was to address the mounting opioid crisis, according to Borgasano. “By taking paper out of the hands of the patient, we’re ability to reduce the risks of fraud, diversion, and doctor shopping.” And when it comes to controlled substances, which carry a high risk of abuse and dependency, no stone can be left unturned.
In the DEA’s internal final rule, nothing was, said Borgasano, who broke down some of the key points included in the requirements:
- Before providers are approved for EPCS, they must validate their identify and demonstrate that they’re authorized to prescribe controlled substances, and that their DEA number and license are in good standing — even if they’re already prescribing controlled substances on paper.
- Two-factor authentication is required before a provider can sign an order and send it to a pharmacy. This can include a combination of passwords, tokens, and fingerprint biometrics, said Borgasano. “To bind the identity of the provider with the two-factor authentication credential, you need to enroll those modalities in a compliant way.”
- To gain permission in the EHR to use the EPCS workflow, providers need a set of individuals to actually configure the workflow, and another set to approve those permissions. These workflows, he added, must be kept separate from those who are conducting identify proofing. Once that’s completed, providers can do EPCS using two-factor authentication for each transaction. All of this, of course, must be monitored and reported on from an auditing perspective.
It’s a lot, for sure. But the idea is to establish what DEA has termed ‘non-repudiation with absolute certainty.’ What that means, according to Borgasano, is “if there’s an incident of diversion, you can trace back, using audit records, that it was a specific provider who wrote a specific prescription for a patient for this medication, using this approved process.”
And although the federal mandate is still months ago, individual states have already gotten into the game; 10 have laws requiring electronic prescribing for controlled substances, and 17 more have passed laws that will soon take effect.
“EPCS is becoming an inevitability,” noted Borgesano. “And in order to comply, you must meet all of these unique requirements.”
Of course, there are other factors at play, including patient satisfaction, patient safety, fraud detection, and maintenance costs.
For Coule, all of these are drivers. But as the father of a child with ADHD, it’s also a personal matter. Like many parents, he has had to contend with the “archaic” and difficult process of having to physically pick up a prescription — even if it’s a refill. More than once, he has thought, “there has to be a better way.”
In addition to being a “big patient dissatisfier,” paper prescriptions also resulted in diversion problems, whether it was from stolen reams of Rx pads or authentic-looking forms that were, in fact, fraudulent.
“It’s one of the struggles we were trying to solve with EPCS.”
But, as with so many challenges, it’s not as simple as merely plugging in technology, said Lang. When the Strengthen Opioid Misuse Prevention (STOP) Act was passed in 2017 to curb opioid abuse in North Carolina, it immediately became a priority. But it had to be done “in a way that best addressed workflow for the physicians so that it increases efficiency and doesn’t just become one more burden within the EMR.”
Other hurdles exist as well, particularly in unique environments like the emergency department. At CaroMont, there’s a limited number of pharmacies available to fill prescriptions outside of normal business hours, meaning workflows have to be identified to accommodate different scenarios. Another occurs when patients identify a particularly pharmacy as the preferred location, then change it after the prescription has been sent.
In both cases, there’s simply too much room for error, said Lang. To that end, her team worked to provide a “seamless approach” that enabled providers to access and review databases in the EMR and send an electronic prescription to the preferred pharmacy, while using Bluetooth capability so that the device never leaves the pocket. “That integration and attention to detail has helped us address most of the constraints we were facing,” she said.
Finally, both Coule and Lang recommended making sure the right people are involved are in the process from day one, from clinical staff to project managers. Coule’s team put together a work group that represented a wide cross-section of specialties and roles, and ensured “close collaboration” between physician leaders and IT. At CaroMont, clinical champions were recruited to help users overcome hurdles, and keep leaders informed.
“This isn’t for the faint of heart,” she said. “It’s an enormous project with a lot of moving pieces and parts, and it can easily get off track.”
But, if executed right, it can help create a more efficient environment for providers, and for patients and caregivers, a “better way.”
To view the archive of this webinar – Readying Your Organization for the Impending EPCS Deadline (Sponsored by Imprivata) – please click here.