Jarrod Shapiro, DPM
Practice Perfect Editor
Assistant Professor,
Dept. of Podiatric Medicine,
Surgery & Biomechanics
College of Podiatric Medicine
Western University of
Health Sciences,
St, Pomona, CA

EPCS: Electronic Prescriptions for Controlled Substances…Maybe

Here comes something that will add enormous added value to your electronic medical records system…someday. I’m referring to the EPCS. EPCS stands for “Electronic Prescriptions for Controlled Substances.” This one’s going to make you happy…eventually. In March of 2010, the DEA published a new rule pertaining to controlled substances that amended the prior rules regarding how these medications could be prescribed. As we’re all aware, prescriptions for controlled substances – most notably opioid analgesics – required a written document by the prescribing professional. See Figure 1 below for a quick reminder of scheduled drugs. The vast majority of us still prescribe controlled substances this way, while just about all other drugs are easily prescribed electronically.

Figure 1. Scheduled Drugs¹

Schedule	Definition	Examples
I	High abuse potential. No known medical use. Lack of accepted safety.	Heroin, LSD, marijuana
II	High abuse potential.	Morphine, oxycodone, fentanyl
III	Lower abuse potential than I and II.	Vicodin®, Tylenol with codeine
IV	Low abuse potential.	Lorazepam (Valium®), Midazolam (Versed®)
V	Lowest abuse potential.	Robatussin®

The DEA’s new rule became effective on June 1, 2010. The EPCS ruling allows practitioners the option (don’t worry, the ruling is optional) to use their EMR systems to electronically submit a prescription for controlled substances instead of hand-writing them. The ruling also allows pharmacies to receive, dispense, and archive the information.² Gone would be the days of worrying about patients altering our prescriptions or stealing our DEA numbers. We could finally lose the prescription pad for good.

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If it's so good why hasn’t it happened yet?

Despite the fact that it's been about a year and a half since the ruling went into effect, the vast majority of physicians in the United States still use paper to prescribe their scheduled drugs.

Why is that the case?

Is it because the EMR companies have delayed certification as required by the federal government? Nope. The EMR system I currently use, Health Fusion, is certified and ready to go. According to a 2011 survey of ePrescribing by the Brown-Wilson Group, Inc. “Pharmacies, vendors, and state laws need to catch up”.³ Recently I spoke with an MD colleague who blamed the pharmacies for taking too long to come online.

It’s easy to hypothesize why pharmacies and states would have a difficult time implementing this potentially useful option. Pharmacies have to be able to handle prescriptions from various different EMR programs, increasing the complexity of their programs and requiring additional security measures. Additionally, since pharmacies will also be monitoring and archiving prescribing information, this ability has to be set up. Granted, much of these systems are already in place for other prescribing practices, but I’m willing to give the pharmacies the benefit of the doubt.

Since prescribing pain medications can be such a hassle with its associated risks, I love the idea of eliminating one major step in the process – handing patients a script - and sending them electronically directly to the pharmacy.

What about the states? This one seems like a no-brainer. Laws for prescribing other drugs already exist, so the states should be able to quickly create laws with the necessary modifications for scheduled drugs. Of course, we are talking about governmental bureaucracy, so we’ll be lucky to see this happen in our professional lifetimes. I always found it strange that all the EMR systems I’ve used never let me ePrescribe the one set of drugs that I really wanted to go directly to the pharmacy. Since prescribing pain medications can be such a hassle with its associated risks, I love the idea of eliminating one major step in the process – handing patients a script. Unfortunately, it looks like we’re going to have to wait a little longer. I won’t hold my breath.

Best wishes.

Jarrod Shapiro, DPM
PRESENT Practice Perfect Editor
[email protected]

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References:

Controlled Substance Schedules. Office of Diversion Control, US Department of Justice Drug Enforcement Agency. https://www.deadiversion.usdoj.gov/schedules/index.html#list Last accessed July 6, 2012.
Electronic Prescriptions for Controlled Substances: Interim Final Rule with Request for Comment Questions and Answers for Prescribing Practitioners [as of 3/31/2010]. Office of Diversion Control, U.S. Department of Justice Drug Enforcement Agency. www.deadiversion.usdoj.gov/ecomm/e_rx/faq/practitioners.htm Last accessed July 5, 2012.
2011 State of the ePrescribing Industry. Black Book Rankings®, Brown-Wilson Group, Inc. publishers. 2011.