Before we know it, 2021 will be here. With it comes a barrage of federal and state mandates that might catch many behavioral health organizations off guard. For instance, there are EPCS and PDMP mandates with mandatory compliance rules for organizations to follow and many take effect in just a couple of months! 

What are these mandates? Why are they popping up now? What do you need to do to ensure your organization doesn’t fall out of compliance? All good questions. These mandates were announced some time ago, but it’s easy to have overlooked them until now. We all get busy and have plenty to do. Don’t panic — there’s still plenty of time. Here’s how you can get prepared and streamline your operations in the process.

What are EPCS Mandates?

EPCS stands for Electronic Prescription of Controlled Substances. EPCS mandates require that certain controlled substances be prescribed using an electronic prescription service rather than a paper prescription. This ensures that such prescriptions are easily trackable in state Prescription Drug Monitoring Programs (PDMPs) to help prevent prescription opioid abuse and maintain client security. 

A number of states already have mandates which require electronic prescription of either certain controlled substances or all prescriptions. 2021’s EPCS mandates are taking effect in many more states on the first of the new year. 

The “Every Prescription Conveyed Securely Act,” will “require prescriptions for controlled substances covered under Medicare Part D to be transmitted electronically, starting on Jan. 1, 2021.” Certain states have later dates under which their EPCS mandates take effect and begin to be enforceable by the Centers for Medicare and Medicaid Services (CMS). Either way, now is the time to get ready.

Where Do PDMPs Fit In?

Prescription Drug Monitoring Programs are part of a nationwide effort to monitor client access to controlled substances. As with EPCS mandates, the goal is greater security and public health. The Medicaid PARTNERSHIP Act, included in the SUPPORT Act, requires providers to check client drug history in a PDMP before prescribing controlled substances.

Why Now?

These mandates are largely due to the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, or SUPPORT Act. Signed into law in 2018, the SUPPORT Act aims to address the nationwide epidemic of opioid abuse which has taken countless lives and ruined many others. 

The EPCS and PDMP provisions in the SUPPORT Act are intended as safety measures against opioid abuse. By monitoring client access to prescription drugs, increasing substance-use disorder screenings, and taking other measures, the hope is to limit access to controlled substances to those who need them and identify individuals who are at risk of substance abuse or who are displaying drug-seeking behaviors. 

When Do I Need to Be Compliant?

  • The federal mandate requiring electronic prescription of Medicare Part D controlled substances takes effect on Jan. 1, 2021.
  • Many states are instituting their own EPCS mandates on Jan. 1, 2021 as well. These include Arkansas, Delaware, Indiana, Kentucky, Massachusetts, Missouri, Nevada, South Carolina, Tennessee, Texas and Wyoming. 
  • Other states’ mandates take effect later into 2021, with some becoming effective in 2022 and 2023.
  • The PDMP mandate requiring providers to check their state’s PDMP before prescribing controlled substances takes effect nationally on Oct. 1, 2021.

What Do I Need to Do to Get Compliant?

Behavioral health providers must use an EPCS-certified electronic prescribing software. This requires a shift for some providers who still use paper prescriptions, or for those whose current software is slow, unresponsive or not certified for EPCS.

EPCS mandates require a number of additional measures. A partial list includes: 

  • Identity proofing requires that organizations establish proof of identity for the individuals who will issue prescriptions with the electronic prescribing software. This can be conducted in-house according to specific requirements set out by the state or can be done individually by providers obtaining identity proofing via a credential service provider or certification authority.
  • Two-factor authentication ensures that individuals can only access electronic prescription software if they have multiple forms of authorization credentials. This essentially adds an extra layer of security by requiring more than just a password to access prescription software. This extra security may come in the form of a token on a smart card or cell phone, or some sort of biometric data to gain access, like a fingerprint.
  • Logical access controls require two individuals in the practice, one of whom is a DEA registrant, to set up access to electronic prescription software. This can involve making a list of permitted individuals, getting that list approved, having a person to enter the data and another to approve it.
  • PDMP access is also required for the October 2021 mandate. While free and state-run solutions exist, the challenge is establishing access to PDMP data that fits in with an organization’s workflow. 

What Are My Biggest Obstacles Moving Forward?

  • Compliance is a major hurdle for many organizations. The process of setting up these protocols will be different for every organization, but it is fairly involved and not something that can be achieved overnight. Luckily, Qualifacts+Credible offers solutions which simplify the process and integrate these protocols into your workflow.
  • And speaking of workflow .. integration is another challenge. If you’re using outdated or inflexible EHR software which does not allow for implementation of these protocols, or for easy electronic prescribing, can slow your organization down and lead to many headaches. 
  • The PDMP mandate also poses issues for maintaining smooth workflows. Having to consult a PDMP outside of a normal EHR workflow could slow clinicians down significantly. An EHR which doesn’t offer integrated PDMP data is often the culprit.

What Kind of EHR Solutions Can Help Me Prepare?

You need an EPCS-certified EHR system which is fast, responsive and flexible enough to integrate PDMP data and relevant access protocols. Ideally, you’ll want an EHR designed for the needs of behavioral health providers, since it will have the functionality you need to accommodate necessary changes in care processes. You also want an EHR system which is easy to implement given these time restraints.

What Solutions Do Qualifacts + Credible Offer?

Qualifacts + Credible’s Behavioral Health EPCS-certified EHR platforms have been designed with these all the concerns of behavioral health providers in mind. CareLogic’s Cloud-based construction significantly speeds up implementation. Our new add-ons for CareLogic and Credible eRx fully integrate PDMP data into our EHRs for one easy workflow for your clinicians. Contact us to discuss how our EHR solutions can simplify compliance and streamline your workflow.

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