Atrius Health Weighs in on Electronic Prescribing of Controlled Substances (EPCS) Proposal

Atrius Health recently joined several organizations in providing testimony to strengthen and clarify regulations proposed by the Massachusetts Department of Public Health (DPH) related to Electronic Prescribing of Controlled Substances (EPCS). The proposed changes are part of the provisions of Chapter 208 of the Acts of 2018 to address the state’s opioid crisis and are designed to increase the security of prescription medications.

Electronic prescribing, also known as e-prescribing, is when a doctor writes a prescription and sends it directly to the pharmacy through a secured system. E-prescribing has many advantages which include:

• Improved accuracy of dosages and other written instructions since nothing is handwritten.
• Enhanced patient safety – potential medication interactions and pre-existing medical conditions that can be affected by a new medication can be viewed before the prescription is sent to the pharmacy.
• Reduction of fraud – prescriptions are securely transmitted to the pharmacy via a secure system. Patients no longer have to worry about losing a paper prescription or having it stolen.

Atrius Health launched its electronic prescribing initiative for Schedule II through Schedule V controlled substances more than a year ago. Since that time, we have been rolling this program out to all of our practice locations. The law requires that all prescription medications, regardless of their abuse potential, be electronically prescribed. Although we agree with the premise of the new law, there are a number of circumstances that we and others urge DPH to consider before finalizing the regulations. Those conditions include the following:

• There are insufficient provisions to address unanticipated and/or uncontrollable circumstances that render compliant electronic prescribing infeasible or impossible, e.g., weather-related power outages, phone carrier outages, or when a pharmacy system is off-line.
• Some cases are out of the prescriber’s control and the electronic system converts the prescription to a fax, such as when patient instructions are too long or complicated or when a third-party software malfunctions. In both of these cases, the prescriber may intend and attempt to prescribe the medication electronically, but the system defaults to sending a fax.
• Similar to compounded drugs, infusion drugs should be excluded from the EPCS requirements because they often require the prescriber to include lengthy and complicated instructions that make it difficult, if not impossible, for electronic prescribing.

Our testimony also recommends that DPH incorporate language similar to the New York State Department of Health, which enacted similar requirements several years ago. The New York State regulations acknowledge that current standards allow only a limited number of characters for the prescription instructions and permit exceptions to the EPCS requirements in those situations when more detailed instructions are required.

Atrius Health also suggests that DPH incorporate language into its final regulations that exclude the requirement that pharmacists must verify a practitioner has received a waiver or is exempt from the EPCS requirements. It would be difficult, if not impossible, for pharmacists to verify these waivers or exemptions while still ensuring that patient care is not compromised.

We believe these modifications will still support the safe electronic prescribing of medications while also allowing for conditions that are beyond the prescribers control.

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