Three Key Considerations for Successfully Enabling Electronic Prescribing of Controlled Substances

In 2010, the U.S. Drug Enforcement Administration (DEA) passed an interim final rule allowing controlled substance to be prescribed electronically. There are many benefits to electronic prescribing of controlled substances (EPCS), including improving efficiency of clinical workflows, decreasing patient wait times at pharmacies and minimizing the potential for medication errors, inaccuracies or forgeries. However, because these medications are heavily regulated due to the risk of diversion and abuse, the DEA rule mandates that several criteria be met for EPCS.

For example, EPCS must be authorized by the state board of pharmacy, the electronic medical records (EMR) system and other software used for EPCS must be certified, the pharmacy must also be certified to accept prescriptions for controlled substances electronically, and proper two-factor authentication technology must be used to authorize the prescriber at the time the prescription is entered for each patient.  

Fortunately, the industry has made significant progress putting the necessary infrastructure in place to meet the requirements for EPCS, and organizations are starting to develop project plans to implement EPCS. While many elements of an EPCS project plan will mirror those of any major initiative, there are several key considerations to successfully enable EPCS, including:

1. Understanding the Broad Organizational Requirements
A successful EPCS project requires multiple viewpoints and inputs as it impacts IT, pharmacy, compliance and clinical operations. It is critical to start with the vision that EPCS goes beyond the boundaries of IT and therefore the plan must sufficiently incorporate the objectives and requirements of each group affected by EPCS.  Building the right cross-functional team starts with an internal champion, and typically chief medical information officers (CMIOs) are the ideal candidate to spearhead the initiative because they represent both the clinical and IT perspective, and have visibility into the entire organization.  Other team members to consider include IT leadership (such as CIO or an IT director), the head of pharmacy, EMR analyst(s), compliance offers and others.  

2. Enabling Clinical Adoption
The success of an EPCS project depends on clinical adoption, so it is important to make technology and policy decisions that improve clinical workflows and minimize interruption while also meeting regulatory requirements. The full benefits of EPCS can only be realized if the process is efficient, as disruptions to normal routines—even if only for a few seconds at a time—can add up to a significant amount of wasted time that could be better spent treating patients. Therefore, project teams need to understand how EPCS will be used within their organization, including the scenarios when EPCS will be used and the frequency of prescriptions for controlled substances. With this knowledge, the proper technologies decisions can be made.

3. Implementing the Right Processes for Sustained Success
Another important consideration for EPCS project success is instituting the right processes to comply with DEA requirements and sustain a successful EPCS initiative over the long term. For instance, IT needs to establish flexible and scalable processes for assigning administrator rights to the EPCS platform as well as for auditing the various components of the system to ensure a simple, seamless process as EPCS adoption increases across the organization.

As organizations implement EPCS project plans, taking these few steps should help keep initiatives on track. With the right team in place—including a project leader with a holistic understanding of the impact of EPCS—as well as a thorough evaluation of clinical workflow requirements and well-thought-out IT process, organizations can take the first steps toward EPCS success. Conversely, the failure to do so could put EPCS projects at risk and prevent providers and patients are able to realize the significant benefits of prescribing controlled substances electronically.