4 Steps to Implement e-Prescribing
Are you are thinking about adding e-prescribing to your practice? Or do you practice in New York (where you must begin e-prescribing by March 27th) and don’t know where to start? Here’s what you need to know:
1. Understand the law – federal and state
Most federal law relevant to e-prescribing involves electronic prescribing of controlled substances (EPCS). The software vendor must provide you with proof of certification by the DEA or by third party audit. Not all vendors have this certification, so not all vendors can offer EPCS. The DEA also requires identity-proofing to allow for two-factor authentication. The two factors could be something you know (such as a password), something you have (such as a token), or something you are (such as biometric information). Your vendor should be able to guide you through these requirements.
State law will vary. In New York, there are very few exceptions to the mandated e-prescribing of all prescriptions, including prescriptions for controlled substances. Also, New York requires prescribers to register their system with the state, and send notification to the state when e-prescribing was not possible (due to a technology failure, for example).
2. Prepare to utilize either an electronic health record with e-prescribing that includes EPCS, or a stand-alone e-prescribing system that includes EPCS
If you already have an electronic health record (EHR) system, you may be able to add an e-prescribing system to it. You will need to confirm that the e-prescribing system includes EPCS. If you are in New York, and your EHR system will not support EPCS, or you don’t have an EHR, you will need to invest in a stand-alone e-prescribing system that includes EPCS.
When purchasing an e-prescribing system, cost is just one of many factors to consider. No-cost e-prescribing systems may be available, but remember, nothing is really free. As my colleague David Cash always says, “Free is not a sustainable business model.” You may have to pay for 24/7 access, additional users, or ad-free access. You also need to consider the support that will be provided and whether you can accept the contract terms.
3. Comply with any state requirements
4. Get up and running
You will need to get trained on the system you select and notify patients that you are now prescribing electronically.
Does this all sound overwhelming? You’re not alone – it is a big task. If you would like more information, I encourage you to visit PRMS’ website –www.psychprogram.com/risk-management/2014-NY-e-prescribinginformation.html. I’ve made a lot of useful information available to everyone, including a recording of a program we presented in New York last month. While it addresses New York law, it may be useful to those outside of New York as well. The handouts are also available and include the following:
1) An article titled “E-Prescribing Vendor Contracts: What You Need to Know”
2) Questions to ask e-prescribing vendors
3) E-Prescribing vendors with certified stand-alone EPCS currently available
4) And more!
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Donna Vanderpool, MBA, JD – Vice PresidentAs Vice President of Risk Management, Ms. Vanderpool is responsible for the development and implementation of PRMS’s risk management services for The Psychiatrists’ Program. Ms. Vanderpool has developed expertise in the areas of HIPAA and forensic practice, and has consulted, written and spoken nationally on these and other healthcare law and risk management topics. She most recently wrote a chapter concerning the risks of harm to forensic experts for Robert L. Sadoff, MD’s book Ethical Issues in Forensic Psychiatry: Minimizing Harm, (Feb. 2011/Wiley). Ms. Vanderpool received her undergraduate degree from James Madison University, and her MBA and JD from George Mason University. Prior to joining PRMS in 2000, Ms. Vanderpool practiced criminal defense law, taught business and legal courses as an adjunct faculty member at a community college and spent eight years managing a general surgical practice in Virginia. |