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ePrescribing Controlled Substances

Posted on August 3, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Back on September 13, 2009 I wrote a post titled, “FDA Approves Pilot Electronic Prescribing of Controlled Substances.” I’d link to the post, but unfortunately the news got sent to me prematurely and so I had to take the post down. It was unfortunate, since there was and still is a lot of interest in being able to ePrescribe controlled substances. In fact, I’d say that not being able to prescribe controlled substances electronically is the current Achilles heal of ePrescribing.

Fast forward to the recent announcement that DrFirst’s announcement of the Nationwide Launch of their ePrescribing Controlled Substances product. Their latest ePrescribing product for controlled substances is called EPCS Gold and is fully certified to meet the prescription processing requirements for Surescripts, the DEA’s requirements in the Interim final rule, and the Identify Proofing requirements set by NIST.

I’m really glad to see ePrescribing of controlled substances moving forward. This will make ePrescribing much more attractive to physicians. Especially physicians that regularly prescribe controlled substances like surgeons and pain doctors.

However, this controlled substance ePrescribing announcement does of course come with it’s limitations. I think they’re described well in this part of the press release:

Prescribers enrolling for EPCS Gold™ will be able to send controlled substance prescriptions electronically after a simple credentialing and identity-proofing process with DrFirst. After providers are certified, they can begin e-prescribing Schedule II-V drugs based on their individual state laws and the ability of the receiving pharmacy to meet the DEA’s requirements to process these prescriptions. To avoid any confusion and eliminate guesswork by providers, EPCS Gold™ automatically detects which substances can be sent electronically.

The two challenges are quite clear: state laws and pharmacy ability to meet the DEA’s requirements. I haven’t done any in depth research on either subject, but I have a feeling that both of these things will be major issues across the country. I’d like to think it won’t be, but knowing the pace of state legislation and pharmacy adoption of these standards I’m not hopeful that they’re ready to receive controlled substance prescriptions electronically.

However, the above step is an important one. You have to have all sides ready to handle the security required to make ePrescribing controlled substances a reality. This is the first step and a very good one.

ePrescribing Controlled Substances Patient Matching Rate

Posted on April 7, 2010 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ve been wanting to write about ePrescribing controlled substances since 9/13/09. In fact, I even did write post about the FDA approving a pilot to do electronic prescribing of controlled substances which I posted on that day. Turns out, it was a press release that was sent to me prematurely, so I hid it from view.

Well, a couple weeks ago, the Drug Enforcement Administration (DEA) released it’s interim final rule on ePrescribing of controlled substances (PDF). John Halamka described some of the most important details of this rule on his blog:

(a) To sign a controlled substance prescription, the electronic prescription application must require the practitioner to authenticate to the application using an authentication protocol that uses two of the following three factors:
(1) Something only the practitioner knows, such as a password or response to a challenge question.
(2) Something the practitioner is, biometric data such as a fingerprint or iris scan.
(3) Something the practitioner has, a device (hard token) separate from the computer to which the practitioner is gaining access.
(b) If one factor is a hard token, it must be separate from the computer to which it is gaining access and must meet at least the criteria of FIPS 140-2 Security Level 1, as incorporated by reference in § 1311.08, for cryptographic modules or one-time-password devices.
(c) If one factor is a biometric, the biometric subsystem must comply with the requirements of § 1311.116.

Halamka also suggests they’ll consider 3 approaches to support strong authentication:
*Fingerprints (Bio-Key software?)
*Hard Tokens (such as those provided by RSA)
*Cell Phones (As Gemalto talked about in this video)

I also recently heard someone tell me that the banking has a 6 percent failure rate for matching people. It’s hard for me to believe that it’s high and that the banking industry is willing to deal with that type of failure rate. Of course, that’s not good enough for controlled substances. So, they’re going to have to find some way to lower the patient matching failure rate. Although, I wonder what the failure rate is with the current model. Seems like electronic prescribing shouldn’t make it any worse than it currently is.