Connecticut’s Electronic Prescribing of Controlled Substances (EPCS) requirement came into effect in January 2018. As Director of Connecticut's Drug Control Division, I often serve as an advisor to state legislators who want to ensure the bills they draft are effective once they become law, so I was very active in the 2017 legislative session. While crafting this bill, we looked at how other states managed implementation of EPCS and worked closely with medical professionals to ensure that our legislation was thoughtful. We knew we had to consider the day-to-day operations of regulators and medical professionals, and ultimately what was best for patients.
As a pharmacist, I have seen firsthand how new technology and new requirements can help or hurt the work of the medical community and those they serve. I also experienced this new reality personally. Since the EPCS requirement became law, a family member had surgery and was prescribed a controlled substance. Not having to take the prescription to the pharmacy and wait, but rather, having the medication ready prior to my arrival was a great relief for us both.
Keeping all of this in mind, below are key considerations for regulators and legislators in other states interested in implementing an effective EPCS requirement:
- Assess what the healthcare institutions, individual practitioners and pharmacies in your state are capable of and how close they may be to implementing EPCS.
- Get a firm handle on the process for two-factor authentication so that you can make sure the implementation timeline in any new legislation is reasonable, especially for healthcare institutions that have a large number of providers that require authentication.
- Many prescribers have multiple different practice locations and may either require multiple two-factor authentications, or may not be able to comply with EPCS at each location where they prescribe. Having an idea of how many prescribers work in these scenarios is helpful.
- Waivers will likely be necessary. A waiver process that includes too many complex steps may significantly impact the department tasked with approving waivers. When constructing a waiver, consider the key data points that provide the most useful information, as well as information that will be useable as you consider future legislative changes. In Connecticut, we have issued 9,524 waivers to date for roughly 30,000 registrations for prescribers, which is more than we expected. We fielded a number of questions from prescribers about how to manage situations where they had access to EPCS at one location but not another. We decided to allow waivers in locations without EPCS access, but required these prescribers to use EPCS when it was available to them.
- Consider the effect of EPCS on the pharmacy at the point of care, as well. How will pharmacists become aware of any waivers? What should a pharmacist do with a paper prescription from a practitioner that does not have a waiver? How will that impact patient care? Our opinion is that the best-case scenario is that pharmacists should not be expected to “police” state e-prescribing or EPCS mandates.
- Review your staffing levels in order to support the volume of increased calls and emails. We found that it was important for us to have a Frequently Asked Questions document that we could update regularly as new questions came in.
No matter what, know that the technology employed is not perfect; these medications form an important part of the treatment for a variety of medical issues; and healthcare is a 24/7 operation. EPCS is an important tool, but not a panacea. I believe having a mechanism that permits some flexibility for prescribers to issue paper prescriptions when necessary, with checks and balances in place will both protect and benefit patients.
We must remember that our number one goal should be providing quality medical care, and we should work to remove obstacles that prevent delivery of that care. Regulating medical care while allowing practitioners to use their professional judgement, and supporting them in making the best decision possible for their patient is a critical and necessary balancing act.
As Director of Connecticut’s Drug Control Division, Rodrick Marriott played a key role in establishing the state’s EPCS requirement. As a result, Connecticut jumped eight places in Surescripts’ 2018 EPCS ranking, just behind New York and Maine, based on the increase the state saw in prescriber enablement and the percent of controlled substances prescribed electronically. Connecticut has been particularly hard hit by the opioid epidemic, with a high rate of drug-related deaths across a relatively small state population. Since the EPCS requirement took effect in 2018, overdose ER admissions dipped and opioid-related deaths have plateaued and could be decreasing. View this map to stay up to date as other states require EPCS, and if you're a prescriber, please visit www.GetEPCS.com to learn how to get started.