Electronic Prescribing FAQs
Q:
A:
Is EPCS mandatory for New York State practitioners?
Practitioners that do not prescribe for controlled drugs do not need to purchase software
for EPCS or register software with the Bureau of Narcotic Enforcement (BNE). As of
March 27, 2015, every prescriber will have to transmit all prescriptions, both
controlled and non-controlled drugs, electronically.
Q:
A:
Will the use of Official NYS Prescription forms be prohibited as of March 27, 2015?
While virtually all routine prescriptions must be transmitted electronically to the patient’s
pharmacy, in few special circumstances, Official NYS Prescription forms may be used:
 Power outage
 Technical failure
 Out-of-state RXs
Q:
A:
I don’t have a computer in my office, can I get an exemption?
The Department of Health can grant exemptions in extenuating circumstances. “Not
having a computer” is not an extenuating circumstance. Prescriptions can be transmitted
using a laptop or tablet device and shortly from a smartphone.
Q:
A:
Will I be able to call in an emergency prescription?
Yes, but. . .
 Only when eRX is impossible and a delay would cause the patient to be harmed
by the delay
 Can only call in up to a 5-day supply
 Must follow-up with report to the NYS Department of Health within 48 hoursi
 Must follow-up with actual prescription within 72 hours for controlled drugs
Q:
A:
I work in a practice with several dentists; can we all use the same system identification?
Each doctor will need his/her own authentication. Software fees are based on a per
provider fee.
Q:
A:
Are dentists required to maintain DEA registration?
DEA registration is required only for dentists that prescribe controlled drugs.
Q:
Why does the DEA require the use of two-factor authentication credentials for the
electronic prescribing of controlled substances (EPCS)?
Two-factor authentication protects the practitioner from misuse of his/her credentials
because the practitioner retains control of a hard token (fob). Authentication based only
on knowledge factors (passwords) is easily subverted because they can be guessed or
hacked or used without the practitioner’s knowledge.
A:
Q:
If I want to prescribe controlled drugs, when I submit the form to register my EPCS
software with the NYS Department of Health’s Bureau of Narcotic Enforcement, how do
A:
I find out the name of the “Third Party Audit/Certifying Organization” and “Date of
Certification”?
Your software vendor interacts with the “audit/certifying organization” and provides the
information you need for your EPCS registration application to you. Keep the
information provided on file in your office.
Q:
A:
How do I get a copy of the EPCS registration form?
Forms for EPCS registration are available from BNE, provided with DEA renewals, and
on the NYSDA website in the “members only” section, www.nysdental.org.
Q:
A:
Can I delegate a staff member to issue prescriptions?
No. Staff cannot issue prescriptions for you currently and will not be able to do it after
March 27, 2015.
Q:
A:
What is a “hard token”?
A hard token must be a cryptographic device or a one-time password device that meets
Federal standards.
Q:
A:
Can a staff member maintain custody of a practitioner’s hard token?
NO. The practitioner is not allowed to have any other person use the token or enter the
knowledge factor (password) to sign prescriptions for controlled substances. Failure to
secure the hard token or password may provide a basis for revocation or suspension of
the practitioner’s DEA registration.
Q:
A:
What should I do if I query the Prescription Monitoring Program (PMP) Registry and
discover that the patient has multiple or large prescriptions for controlled drugs? What if I
find mistakes in the data in the Registry?
Questionable prescribing behavior and mistakes should be reported to the BNE.
Q:
A:
Will I still have to query the PMP Registry every time I prescribe a controlled drug?
Yes, there are currently no eRX solutions that can query the PMP data base.
Q:
A:
Can a pharmacist accept an Official NYS prescription written prior to March 27, 2015?
Yes, pharmacists can fill prescriptions written on the official NYS prescription form prior
to March 27, 2015, the effective date of the new law. Pharmacists can also continue to
dispense refills for prescriptions written prior to March 27th.
Q:
A:
Can I simply email a prescription to the pharmacy to comply with the new law?
An “email” is not considered an electronic prescription because email is not a secure
method of electronically transmitting a prescription. A “faxed prescription” also
is not considered an electronic prescription.
Q:
A:
If I practice at more than one office, are there additional fees or requirements?
The requirements for multiple offices will depend on how each office has configured its
software. “Stand-alone” solutions should not incur any additional fees for adding
locations. Solutions that are integrated with patient software systems may charge an
additional fee for multiple locations. You should check with your software vendor to
determine what applies in your individual situation.
Q:
A:
How do I choose between a “stand alone” and an “integrated” software solution?
If you have an electronic health record or would like to now implement software to create
one, you can select an integrated e-prescribing option. This option is linked to your
patient health record and pulls information from the record to create a prescription. It
then includes a record of the prescription in the patient’s electronic chart. Stand-alone
software is a self-contained system that simply maintains records of patients’ prescription
histories, independent of their complete dental record.
Q:
A:
Can e-prescribing software run on either an Apple/ MAC or Windows system?
Yes, it can be run on either Apple or Windows systems.
Q:
How do I find e-prescribing software that meets all federal and state requirements that
will work well in my practice? Is there an eRx solution that NYSDA recommends?
NYSDA has endorsed a software solution from Henry Schein that is user friendly and
compliant with all federal and state requirements for e-prescribing both controlled and
non-controlled drugs. It is available to NYSDA members at a significant discount
compared with other available products. More information about this solution is included
in the remaining articles in this issue of the New York State Dental Journal. To sign up
today, call 888.988.4804 or visit www.HSePrescribe.com/purchase.
A:
i
DOH has not as yet published information about reporting requirements included in the regulations. It is
anticipated that reports will be submitted either directly to the Health Commerce System (HCS) or the
Bureau of Narcotic Enforcement (BNE).