In the fall of 2018, Congress passed the SUPPORT for Patients and Communities Act, which requires Medicare Part D program participants to use e-prescribing of controlled substances (EPCS) beginning January 1, 2021. In a final rule issued in late 2020, the Centers for Medicare & Medicaid Services (CMS) called for implementing the mandate but delayed enforcement until January 1, 2022. CMS is now proposing to delay enforcement for yet another year, until January 1, 2023.
Surescripts has strong objections to another delay. EPCS enhances patient safety, deters and detects prescription fraud, and reduces healthcare costs by eliminating the burdens of a paper-based system. Most important, it is an effective tool to address the opioid epidemic and is needed now more than ever, as the rate of opioid overdoses continues to grow.
In the comments we submitted to CMS, we argued against delay for three reasons:
1. EPCS can limit senior citizens' exposure to COVID-19
EPCS is a valuable tool for seniors, a group at higher risk of serious illness from infection, as they try to reduce exposure to COVID-19 and its variants. If a prescriber isn't enabled for EPCS, their patients (including at-risk seniors) must make unnecessary office visits to collect paper prescriptions for controlled substances, followed by a visit to the pharmacy to drop off the paper prescription and a second visit to collect the prescription when it is filled. With EPCS, there's no need for multiple office and pharmacy visits that increase potential points of exposure.
2. The opioid crisis shows no signs of abating
The Centers for Disease Control and Prevention (CDC) has stated that the pandemic has likely accelerated the rate of overdoses, which has hit a record high. Solving the opioid epidemic requires an extraordinary degree of experimentation and creativity. Employing technology, such as EPCS, can be an especially effective tactic in fighting the epidemic.
Prescribers need to confidently and securely prescribe opioids to patients who are in legitimate need of pain relief. EPCS allows for opioid prescriptions to be tracked and securely delivered to pharmacies. The electronic nature of the prescription also helps increase patient safety and medication adherence while impeding the fraud and abuse that more easily occurs with paper counterparts. In addition to helping to address opioid fraud and abuse, the use of EPCS creates workflow efficiencies, improves patient safety and ensures that prescribers comply with existing technology.
3. Implementing enforcement mechanisms will encourage faster adoption of EPCS
EPCS is a well-established technology – with over 70% of prescribers and 96% of pharmacies enabled with the tool. Another enforcement delay sends the wrong message to prescribers and pharmacies about the value and importance of the full adoption of EPCS. All efforts should instead focus on accelerating adoption and use. CMS has proposed, and we support, exemptions for any providers who have difficulty accessing the technology necessary to support EPCS. These exemptions should eliminate any concern about potential burdens on small providers.