Welcome to my blog, a place to explore and learn about the experience of running a psychiatric practice. I post about things that I find useful to know or think about. So, enjoy, and let me know what you think.

Monday, October 27, 2014

Electronic Prescribing of Controlled Substances

Calling all New York State prescribers!

On March 27, 2015, all NY State doctors and other prescribers will be required to use electronic prescriptions, rather than paper, except under very extenuating circumstances, like a power outage. This includes controlled substances.

You may recall, I signed up for Practice Fusion EMR a while back, solely so I could use their free electronic prescribing. I did this, largely, because I didn't want a last minute scramble to set up e-prescribing. Unfortunately, they're only just now gearing up to set up prescribing of controlled substances. That's supposed to happen for them in January, and it'll still be free, but I'm a little nervous about waiting til that close to the deadline.

This is what you have to do to set up Electronic Prescribing of Controlled Substances (EPCS):

First, the software you currently use must meet all the federal security requirements for EPCS, which can be found on the Drug Enforcement Agency’s (DEA) web page.

     Note that federal security requirements include a third party audit or DEA certification of the software.

Second, you must complete the identity proofing process as defined in the federal

Third, you must obtain a two-factor authentication as defined in the federal requirements.

Fourth, you must register your DEA certified EPCS software with the Bureau of Narcotic Enforcement (BNE) (Form)

So what is this two-factor authentication?

Individual practitioners will be required to apply to certain Federally approved credential service providers (CSPs) or certification authorities (CAs) to obtain their two-factor authentication credential or digital certificate. The CSP or CA will be required to conduct identity proofing that meets National Institute of Standards and Technology Special Publication 800-63-1 Assurance Level 3. Both in person and remote identity proofing will be acceptable.

 You need 2 out of 3 factors:

Under the interim final rule, DEA is allowing the use of two of the following – something you know (a knowledge factor), something you have (a hard token stored separately from the computer being accessed), and something you are (biometric information). The hard token, if used, must be a cryptographic device or a one-time password device that meets Federal Information Processing Standard 140-2 Security Level 1.
Hard Token?

A hard token is a cryptographic key stored on a hardware device (e.g., a PDA, cell phone, smart card, USB drive, one-time password device) rather than on a general purpose computer. A hard token is a tangible, physical object possessed by an individual practitioner.

I wasn't sure what a biometric was, but according to Wikipedia, it's something like a fingerprint, face recognition, retina scan, or voice recognition. Personally, I'd prefer fingerprint to retina scan, because I'd rather that someone desperate to use my prescribing privileges cut off my finger, rather than cutting out my eye. I've seen that in movies, so I know it can happen.
I've found some companies that do EPCS, and their fees and services vary. The NY State Psychiatric Association had a fair with these vendors this past weekend, but I didn't go, so I checked out their respective websites:

RxNT has an option for e-prescribing only, without an associated EMR. That appeals to me. They charge $650 per year plus $50 one time token fee, plus $25 annual maintenance after the first year. A colleague spoke with them, and they are willing to do group rates, if you have a bunch of people.

They have a video you can watch, but it's not very informative. You can, however, arrange a live demo, or schedule a live webinar, to learn more.

There's also DrFirst. They don't specify price, but will also arrange a demo.

Stratus EMR is  mainly designed for addiction psychiatry.

And ScriptRx, which claims to improve patient outcomes while conserving 24,000 trees each year. They also offer a demo. To their credit, they had the most aesthetically appealing site.

Allscripts was not included in the vendor fair, but they charge $20 per month for their basic E-Rx plan, and and additional $5 per month for the Deluxe plan, without which you can't prescribe controlled substances. I have a feeling there are more hidden charges, but it was hard to tell from the site.

This has been a public service announcement.


  1. If a group was to arrange for a vendor fair for these vendors, do you have an idea of how much to charge each vendor for a booth? We are trying to set up an eprescribing event in NYC, but we don't really know how much to charge. Any feedback would be appreciated. Thank you.

    1. Sorry, no idea about those kinds of logistics. But a group-arranged fair sounds like a good idea.