Electronic Prescription of Controlled Substances in Arizona

One of the blog posts that has recently been most popular was from last April on the electronic prescription of controlled substances. Now it is nearly a year later. So what has been happening in Arizona? Unfortunately, I was busy doing clinical work so I missed a recent committee meeting but I have access to a final draft of a proposed electronic prescription of controlled substance (EPCS) program for Arizona.

The interim final rule by the FDA was published in 2010. I suspect adoption has been slow for any of a number of reasons. IT departments in hospitals and clinician practices are overloaded trying to comply with requirements for the various flavors of Meaningful Use. The complexity of Stage I requirements has steadily grown as they depend on the year when attestation first takes place and ongoing annual compliance. Stage II of Meaningful Use with its new requirements, especially for information exchange /consumer engagement, kicks off this October. Also, planning for the change over from ICD-9 to ICD-10 is also requiring increasing attention.

Provider electronic prescription systems need substantial overhaul in order to comply with FDA requirements. Prescribing workflows that include utilization of the required digital certificates are still being developed. Vendors are busy modifying and testing their systems to enable Meaningful Use compliance. Furthermore, the requirements of Meaningful Use do not include EPCS so there is little incentive to expend resources on this capability.

Finally, there are a number of burdens on pharmacies. Their computer systems need to be upgraded in able to accept and manage EPCS. Other than clinician and customer demand, they have few incentives to do this. Pharmacies are also responsible for arranging third party audits of their controlled substance prescribing systems. The infrastructure needed to perform these audits needs to be developed. Unanswered is how the associated costs will be shared.

Under state leadership and stakeholder involvement, Arizona is poised to move forward on EPCS. The approach will be multi-pronged. Initially, an environmental assessment will be undertaken to study clinician and pharmacy readiness. Next, a limited pilot program at 5 sites will be funded using state resources to develop EPCS capabilities. Educational outreach will be undertaken to spread knowledge on availability of EPCS and answer questions about program requirements. Outcomes will be closely monitored and reported back to organizers. Ultimately, lessons learned will be used to encourage and facilitate EPCS throughout the state.