Surescripts Warns CMS That Delaying EPCS Mandate Puts Seniors at Risk of COVID-19 and Undermines Efforts to Address the Opioid Crisis

The Centers for Medicare & Medicaid Services (CMS) has proposed a one-year delay to a congressionally mandated requirement that Medicare Part D providers transmit all prescriptions for controlled substances electronically beginning January 1, 2021. In our response to CMS’s proposal, we argue that such a delay will put seniors at risk of COVID-19 exposure and undermine efforts to address the nation’s growing opioid crisis.

The Electronic Prescribing for Controlled Substances (EPCS) mandate is a provision of the 2018 SUPPORT Act which was passed with overwhelming support in the House and Senate to address the opioid epidemic that is ravaging communities across the country. Congress included the mandate provision based on evidence that EPCS reduces illegal diversion by eliminating theft and use of fraudulent paper prescriptions. EPCS also supports a fully verifiable and traceable history of controlled substance prescribing transactions. 

As we argue in our comment letters to CMS, now is hardly the time to slow down efforts to address the opioid epidemic, which has only worsened over the past two years. The number of Americans dying from drug overdoses hit a record in the 12-month period ending in March. New data from the Centers for Disease Control and Prevention show that there were 73,860 overdose deaths reported in the 12 months through March 2020—the highest of any year-long period in recent U.S. history. Overdose deaths were already increasing significantly at the start of the COVID-19 pandemic. But over the past nine months, more than 40 states have reported increases in opioid-related mortality according to the American Medical Association's Issue Brief: Reports of increases in opioid and other drug-related overdose and other concerns during COVID pandemic.

We believe CMS’s proposed delay will also put seniors at greater risk of contracting COVID-19. With seniors particularly vulnerable to more severe outcomes if infected by COVID-19, healthcare providers are increasingly using telemedicine to treat them and avoid unnecessary infection risks posed by in-office visits. Seniors whose providers have not implemented EPCS are forced to travel not only to the provider’s office to pick up a paper prescription, but also to the pharmacy to drop off the paper prescription and to pick it up once filled. We see no value in increasing the number of potential points-of-exposure for seniors who are already at increased risk of severe health outcomes. 

Given the severity and scope of the two public health crises the nation is facing—the opioid epidemic and the global COVID-19 pandemic—we have urged CMS to reverse course. We believe there is an absolute and urgent need to comply with the statutory requirement that the EPCS mandate be implemented on January 1, 2021.

Read Surescripts’ full comments and download Surescripts 2019 National Progress Report to learn more about the progress made by the Surescripts Network Alliance in using EPCS to combat the opioid epidemic.