Electronic Prescriptions for Controlled Substances (EPCS)

NewCrop, the leading supplier of electronic prescribing services, is pleased to announce EPCS-G2, a comprehensive integrated software solution, designed for straightforward installation within a wide variety of electronic medical systems.

Exostar provides our identity infrastructure. Thus, we have addressed the complexities of EPCS by combining Exostar’s business process expertise with NewCrop’s skills and experience, gained over 15 years of integrating prescribing systems with a wide range of electronic health records and integrated health care delivery systems.

EPCS-G2 can be utilized via an integrated suite of data services or by the use of dedicated and optimized user screens.

EPCS-G2 is an ideal solution for EHRs wishing to quickly, and at low cost, provide EPCS to their prescribers.

As electronic prescribing has grown in use, approaching 70% of prescriptions nationwide, a significant impediment to wider acceptance has been the inability to transmit scheduled drugs due to the Drug Enforcement Administration’s (DEA) policy. In June of 2010, DEA published rules allowing EPCS under clearly specified conditions. Since DEA’s primary role is to prevent “diversion” of narcotics, sedatives, stimulants, and other scheduled drugs (2,3,4,5) from accepted medical practice to unregulated use, the focus of these rules was “non-repudiation.” Thus, the requirements include a meticulous process mandating that the identity of the prescriber is known and the prescription can be, without exception, attributed to this prescriber. The former is accomplished through “identity proofing (IP),” the latter, through “2nd factor authentication (2FA)” (The “1st factor” is usually the initial EHR password).

NewCrop began providing electronic prescribing services in 2003. Our comprehensive package includes clinical drug review, managed care formularies, and Clinical Routing and Benefit/Drug History, in a single user interface or as individual components via .NET web services. The system has been installed in 200+ EHRs, nationwide.

NewCrop provides a versatile software tool kit that greatly decreases the effort needed by an EHR to incorporate the many drug/prescribing elements needed for Meaningful Use and Medicare: a simple Build versus Buy choice. Furthermore, pricing is structured to support the Buy decision. Of equal, or greater, importance is a simplified process for Clinical access: NewCrop’s pre-certified services allow for an expedited certification review, in most cases limited to a short Clinical session to simply confirm the NewCrop installation. EPCS adds a second level of review: a DEA-mandated external audit, confirming correct installation of identity proofing and 2nd factor technology. Since the EPCS-G2 module is pre-certified by a complete external audit, only an expedited review, analogous to the Clinical “screen” certification is needed. Following this audit, each EMR-IS will receive a statement of certification, to be presented to Clinical. Thus, EPCS further magnifies the value of the NewCrop Build vs. Buy decision.

200+ EHRs now use NewCrop e-prescribing services. 90% have chosen to utilize integrated NewCrop prescribing workflow. As a result, NewCrop has the experience and expertise to quickly provide a transparent workflow via an easily installed data interface. Although EPCS does consist of many new capabilities, the process of integration is essentially identical to established NewCrop processes. Thus, we are quite certain that, assuming familiarity with XML posting and ASP.Net web services, the project can be completed with 1 week of development.

Ongoing use is maintenance-free. The NewCrop interface automatically creates new accounts and users upon first entry to the system. Once the XML interface is built and populated, no further steps are required: new accounts, users, and patients are added automatically without any preregistration processes.

  • The details of what is included in EPCS-G2 would have to be duplicated by any EHR wishing to build from the ground up. Here, in approximate order of what the user sees, are the components provided in the NewCrop package:
  • Initial prescriber set-up: DEA specifies a series of complex and convoluted steps to allow EPCS, starting with the first-time set-up. Since the doctor will complete this process only once a year, we have built an intuitive “wizard” sequence, presenting the user, at each step, with only the specific actions appropriate to their status and role.
  • Access controls: the first thing that the prescriber encounters. This is a complex set of DEA-specified rules defining who and when a prescriber can be allowed to prescribe scheduled drugs and how to withdraw or modify privileges.
  • Identity proofing: The underlying engine for NewCrop is Exostar. In addition to set-up fees, extensive development is needed to connect data services and build the user interfaces.
  • Digital certificate: This must be processed from provisioning by the IP provider through the user workflow and on to the pharmacy. The EHR will pay usage fees.
  • 2nd factor technology: this generates a one-time passcode for each prescribing event. Integration between technology and workflow required. Usage fees apply.
  • Internal exception reporting: DEA specifies monitoring of any unauthorized attempt to access the system. Logs must be created and presented to the user.
  • Paying for all the above: In most circumstances, EPCS will be optional for the individual provider. If EPCS is not included for all users, new billing infrastructure may be needed by the EHR.

NewCrop has always provided an intuitive user experience. Our dedicated EPCS screens are easily learned and will require little, if any, customer support.

The implications of this mix of complexity, development effort, and licensing fees can be accomplished in four ways. In decreasing order of effort and cost:

  1. Do all the above with all development steps. In addition to the internal effort and cost, there is the full end-to-certification by Clinical and the cost of an external auditor, estimated at $40,000+.
  2. Utilize all NewCrop-supplied capabilities as data services. Build out of all user screens. IP and 2FA infrastructure is provided in a standardized set of APIs. External audit effort and cost is set by each DEA audit firm.  NewCrop has developed a relationship with an audit firm that may greatly reduce the audit cost.
  3. Utilize some NewCrop data services and some NewCrop screens. For example, utilize just the NewCrop IP screens and credit-card payment mechanism. Maintain prescribing workflow using NewCrop APIs. Effort and audit cost are midway between options 2 and 4.
  4. Utilize all of NewCrop’s screens, seamlessly integrated into the EHRs workflow. Minimal development is required. Accelerated Clinical and DEA audit reviews.

Our technical flexibility is matched by our business model. We offer EPCS in a variety of formats. In some cases, the prescribers will pay a monthly fee: there need be no cost to the EHR.

The Drug Enforcement Administration created a complex challenge. EPCS-G2 has responded with simplicity in all aspects: installation, maintenance, set-up, workflow, and business aspects.