Monday, September 17, 2012

An Update on Controlled Substance e-Prescribing

I recently had a dialog with Surescripts about the current  state of policy and technology enabling controlled substance e-prescribing.   Here's a summary:

1.       Surescripts is “open for business” nation-wide for e-prescribing of controlled substances (“EPCS”), subject of course to restrictions in state laws that do not permit EPCS.
2.       There are 4 physician vendors who are certified on the Surescripts network to transaction EPCS, and are in fact doing so.
3.       There are 6 pharmacies / pharmacy vendors who are certified on the Surescripts network to transaction EPCS, and are in fact doing so.
4.       There are many other prescriber vendors and pharmacies in our certification pipe-line, including some of the larger vendors.
5.       Admittedly, the actual volume of EPCS is still very modest, but it is beginning to increase.
6.       The primary barriers in my view have been:  the development time and effort the vendors and pharmacies needed to come into compliance with the Interim Final Rule (IFR); the third party-audit (this is a reference to the section required IFR Section 1311 audit, not the Surescripts certification), which is both costly and time-consuming; an incorrect perception that no pharmacies can accept EPCS; vendors’ competing development priorities (Meaningful Use Stage 2, ICD-10, etc.); and having all the docs ID proofed and authenticated in conformance with the Drug Enforcement Agency IFR.
7.       Surescripts has been actively working with vendors to communicate and drive adoption.
8      Surescripts will run a report for me that will illustrate the volume in Massachusetts, which does permit EPCS of all scheduled drugs.  I'll publish that report on my blog.
9   There are about 12 states that either prohibit or limit EPCS.
10.    New York has mandated that all drugs, including controlled substance, be prescribed electronically by 12/31/14.

I hope this is helpful to illustrate the work in progress.    The country is on the right trajectory to e-Prescribe all medications, including controlled/scheduled substances.

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