Are you ready for electronic prescribing requirements? They come into effect soon so make sure you are prepared. Beginning January 1, 2021, all prescriptions for controlled substances and medical devices in Massachusetts must be issued electronically unless covered by an exception.
As we discussed earlier this year in a post called “Electronic Prescribing and Dispensing”, there are steps you need to take to be compliant. If you haven’t already done so, the end of the year is fast approaching, and we recommend you take action. Do you know which controlled substances are included, what the exceptions are, what the responsibilities of the prescriber are and how to meet the requirements without negatively impacting patient care? These are all questions your consultant pharmacist should be able to answer. Below is the information from our earlier post and what we think you should know:
What’s the requirement?
Beginning January 1, 2021, unless covered by an exception, all prescriptions for controlled substances and medical devices must be issued electronically.
What are the exceptions?
When an exception applies, prescribers may issue written or oral prescriptions. Keep in mind that electronic prescriptions are always permitted, even when an exception is applicable. So, what are the exceptions?
- Prescriptions issued by veterinarians.
- Prescriptions issued during a temporary technological or electrical failure.
- Prescriptions issued by practitioners who have applied for and received a waiver.
- Prescriptions issued or dispensed in emergency situations.
- Prescriptions that cannot be issued electronically under federal or state law or regulations.
- Prescriptions issued outside the jurisdiction of the Commonwealth of Massachusetts.
- Prescriptions issued for expedited partner therapy for treatment of chlamydia.
- Prescriptions for compounded drug preparations.
- Prescriptions issued for controlled substances in Schedule VI.
- Prescriptions for durable medical equipment.
- Prescriptions issued prior to January 1, 2023 to nursing home residents.
- Prescriptions issued in response to urgent public health matters.
What follow up must occur?
If one of the exceptions above apply and an oral prescription is issued for a controlled substance in Schedules II-V, the prescriber must issue a written or electronic follow-up prescription to the dispensing pharmacy within seven (7) business days. Additionally, the prescriber must note on the face of the prescription that it is being issued “to document an oral prescription.”
Emergency situations
A pharmacist can dispense a substance in Schedules II-VI upon written or oral prescription in an emergency situation. What is an emergency situation? An emergency situation arises when the immediate administration of a controlled substance is necessary for the proper treatment of the patient, and
- It’s not reasonably possible for the prescriber to generate or transmit an electronic prescription prior to dispensing; or
- The prescriber determines that the electronic prescription requirement would result in a delay that would adversely impact the patient’s medical condition.
Oral prescriptions in Schedules II-V must be followed up with a written/electronic prescription (within seven (7) days) and must include the notation “Issued to Document an Oral Prescription.”
Emergency Prescribing of Schedule II Controlled Substances
The follow-up written or electronic prescription must include the additional notation, “Authorization for Emergency Dispensing.”
Time-Limited Waiver
DPH may approve a time-limited waiver for a prescriber or facility. A prescriber may issue oral and written prescriptions for a limited time if issued a waiver. If applying for a waiver, the applicant must fill out the Drug Control Program form and provide supporting documentation.
We are always working with our facilities to ensure they are aware of the newest clinical and regulatory changes. We encourage you to share this information with all prescribers and if you have additional questions or need help preparing to be compliant, please contact us.
For complete details, please read Circular: DCP 19-12-108 Electronic Prescribing and Dispensing Manual.
The Consultant Pharmacists at OctariusRx provide guidance on safe medication management, survey readiness and cost savings to ambulatory healthcare facilities/surgery centers, senior care facilities and pharmacies We also help individual patients optimize their medications to improve their quality of life and save money. Contact us for assistance.
