2015 User Conference Electronic Prescribing of Controlled Substances (EPCS) April 25, 2015 Presented by: Peter Minio Product Manager, Pediatric and Primary Care Solutions Room Monitor: Jeanette Jones Services Support EHR Session

2015 Office Practicum User Conference Learning Objectives ●Background information about EPCS and I-STOP. ●Readiness for EPCS. ●Identity-Proofing (IDP). ●How OP has implemented EPCS.

2015 Office Practicum User Conference Background The Controlled Substances Act of 1970 mandated a high level of governance over controlled substances in order to prevent illegal uses. ePrescribing controlled substances (Schedule II-V) was made legal by the DEA in ○ Adopted to further reduce fraud and abuse. ○ Stringent requirements to address concerns in an electronic environment. ○ Not mandated on the federal level. ○ States have right to further regulate.

2015 Office Practicum User Conference Benefits of EPCS Reduce fraud and abuse. Improve patient safety. Single workflow for all medications with more efficient record keeping. Reduce the cost of regulatory compliance. Be audit-ready.

2015 Office Practicum User Conference Readiness Software providers (e.g., OP) must implement the capabilities, but also complete both a certification and a third-party audit. Many EHR vendors and pharmacies are not ready. ○ As a result, provider adoption is low.

2015 Office Practicum User Conference State Readiness ●Currently 48 states and the District of Columbia allow ePrescribing. ○Missouri and Montana do not permit EPCS. ○Vermont does not permit Schedule II drugs to be transmitted electronically. ●More than 70% of pharmacies nationally are certified for EPCS.

2015 Office Practicum User Conference I-STOP - New York ●Mandates ePrescribing for both legend drugs (any drug that requires a prescription) and controlled substances by March 27, o On March 13, 2015 Governor Cuomo signed into law a bill which delays implementation until ●Requires providers check the Prescription Monitoring Program (PMP) and obtain a confirmation number before prescribing a controlled substance. ●On March 13, 2015 Governor Cuomo signed into law a bill which delays implementation until 2016.

2015 Office Practicum User Conference Prescriber Requirements ●Prescribers must go through a form of electronic authentication, otherwise known as identity-proofing (IDP). ●Each provider must be issued “two-factor authentication” credentials. ○ Two-factor authentication is when a user provides two forms of identification (something they know and something on them): ■ Password. ■ Hard or soft token. ■ Biometric (fingerprint scan). ■ Example: ATM card and PIN number. ●Credentials to each user are granted access with logical access controls.

2015 Office Practicum User Conference What is OP Doing About EPCS? ●Office Practicum has partnered with DrFirst to deliver EPCS functionality. ○ DrFirst uses Experian (a major credit reporting bureau) for IDP. ●Each provider will need to complete an IDP process through Experian. ●On March 13, 2015 Governor Cuomo signed into law a bill which delays implementation until ○ Additional charges apply.

2015 Office Practicum User Conference IDP Process Sign an add-on agreement and provide necessary additional information: o Unique address per provider. o DEA#, NPI, Address A hard token will be issued to each provider. o You may also download a soft token.  Important Note: Per DEA regulations, soft tokens must be utilized from a different device than the device prescribed from. IDP is a 7 Step process performed online. o Must provide personal information such as Social Security Number, DOB. o Must answer 3-4 questions pertaining to personal financial history.

2015 Office Practicum User Conference Example of Financial Questions

2015 Office Practicum User Conference Step 7 of IDP ●Once Step 6 is completed, Experian will send a confirmation code to the provider’s home address. ●The provider must log back into the IDP system and enter the confirmation code in order to complete Step 7.

2015 Office Practicum User Conference Logical Access Control (LAC) ●LAC will be available from within OP for administrative users only. ●Used to make a provider that has completed the IDP process either active or inactive.

2015 Office Practicum User Conference Provider Dashboard ●A dashboard will be available from OP where providers may enable/disable hard/soft tokens and biometric devices. ●Prescribers are allowed to have more than one device associated with their identity.

2015 Office Practicum User Conference Rx Signing Screen

2015 Office Practicum User Conference New Rules ●A controlled substance: ○ Can only be sent electronically to a pharmacy or printed for dispensing once. ■ Exception: If the transmission failed. ○ If printed after being sent or previously printed, it will be marked as a copy and instruct the pharmacist not to dispense. ●Once a controlled substance is sent or printed, it cannot be edited.

2015 Office Practicum User Conference NADEAN ●Certain drugs require a Narcotics Addiction DEA (NADEAN) Number (e.g., Suboxone) to be included in the pharmacist notes.

2015 Office Practicum User Conference HGB ●Drugs that contain gamma-Hydroxyburtric acid (e.g., Xyrem) must contain a reason for prescribing in the pharmacist notes.

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