Preparing for EPCS and the New NCPDP SCRIPT Standards

The healthcare industry is undergoing a significant transformation as provider organizations leave behind outdated paper processes and embrace e-Prescribing. Federal and state regulations are driving this shift, aimed at enhancing patient safety, reducing errors, addressing the opioid crisis, and decreasing costs. Staying informed and prepared for evolving regulations is crucial for compliance and effectively managing medication.

In 2024, important regulatory updates were announced that affect Medicare Part D e-Prescribing. This includes important considerations for the Centers for Medicare and Medicaid Services (CMS) Electronic Prescribing of Controlled Substances (EPCS) program for long-term care beneficiaries. Compliance actions for long-term care (LTC) were exempted from the original effective date but are now scheduled to begin on January 1, 2028.

While this transition period allows healthcare organizations time to establish new processes to adopt the new standards, it’s crucial to begin preparations now to avoid last-minute integration challenges and risk of non-compliance. There are some key steps that providers can take now to help facilitate a seamless shift to e-Prescribing and full EPCS compliance.

Key Regulatory Updates in 2024

On July 17, 2024, an impactful final rule known as the Health Information Technology Standards and Implementation Specifications, which applies to the Medicare Prescription Drug Benefit Program, came into effect. This rule names a new version of the prescribing standard to be effective from that date, with a transition period during which both the old and new versions of the National Council for Prescription Drug Programs (NCPDP) SCRIPT standard can be used.

From January 1, 2028 onwards, only the new version (2023011) of the NCPDP SCRIPT standard must be used for Part D e-Prescribing. The new standard offers various advancements relevant to providers in long-term and post-acute care.

Additionally, a final rule known as the CY 2025 Medicare Physician Fee Schedule was published in December 2024. This rule finalizes important considerations for the CMS EPCS program for long-term care beneficiaries. It delays the previously announced compliance date of January 1, 2025 to allow for more time for the industry to be compliant. The rule further aligns the implementation timeline of the CMS EPCS program with the adoption of the new NCPDP SCRIPT version 2023011 standard. For prescribers who do not meet the compliance threshold based on prescriptions written for a beneficiary in a long-term care (LTC) facility, CMS extended the earliest date of compliance actions to no earlier than January 1, 2028. Payer and/or state entities may also choose to create their own regulations ahead of this federal deadline.

How to Prepare Ahead of the Deadline

Preparation ahead of the 2028 deadline will help ensure successful compliance. The process begins with spreading awareness of e-Prescribing benefits within your organization as well as to your prescribers. Electronic prescribing brings a host of benefits: it reduces transcription and communication errors, checks for drug interactions, streamlines order processing, and keeps resident health data accessible. Additionally, automated electronic ordering validates prescription data, helping to minimize errors, adverse drug events, and controlled substance misuse.

The following steps can aid in effective preparation for EPCS:

1. Federal and state regulations around EPCS specific to your operation should be reviewed and understood. Some state regulatory requirements may be more restrictive than the above, and pharmacy payers supporting those requirements may apply their own restrictions.
2. Determine qualifications for exemptions or waivers and consult with your legal counsel to be sure to be aware of all obligations.
3. Engage your prescribers — prescriber buy-in is key to success.
   • Education for prescribers is essential. They will need to get used to signing orders electronically and may need time and training to get used to the new workflows.
   • For consistency with other prescriber workflows, adoption of mobile app usage for signing orders, reviews, access to resident information, etc., can help improve their experience.
4. Evaluate integration capabilities and existing applications. Do you have the optimal technology in place?

PointClickCare integrations and applications provide the capabilities needed for EPCS compliance with eMAR, Integrated Medication Management (IMM), and Practitioner Engagement (mobile). We are dedicated to supporting our customers as they navigate the adoption of EPCS, and our team will provide the necessary support throughout the process of EPCS implementation to ensure seamless transition to the new e-Prescribing standard by January 1, 2028.

This information is provided for information purposes only – it does not constitute legal advice.