1. As you probably know a new NYS bill and a new NYS DOH memo affect the status of EPCS at your facility:
· The Bill. A bill in the New York State Senate proposes to “Amends Public Health Law § 281 and Education Law § 6810, to allow non-electronic prescriptions to be made through the long-established mechanism of oral prescriptions being submitted by nursing homes for their residents.” This bill has been approved by the Health Committee, the Senate and the Assembly.
· The Memo. A memo from Commissioner Howard A. Zucker of New York State DOH dated March 16, 2016 provides for a blanket one-year waiver for EPCS for all nursing homes.
2. Assuming the bill is signed by the governor the implications for your facility are as follows:
· Until March 26, 2017 all orders are exempt from EPCS. If you want, however, to send Controlled Substances electronically to the pharmacy, whether regular or discharge orders they must conform to EPCS regulations. (Without EPCS the VISUAL EMR system actually faxes Controlled Substances to the pharmacy. The facility then follows up by sending a written order in triplicate to the pharmacy. You can continue to do this until March 26, 2017.)
· After March 26, 2017 telephone orders will still be exempt from EPCS, but written orders will not be exempt. It is our understanding that all discharge orders will need to be sent to local pharmacies using EPCS.
3. To be ready for the March 26, 2017 deadline we recommend:
· Your doctors acquire IdenTrust tokens for Dual Authentication, and the vEMR Mobile Software for remote signing.
· Your facility use EPCS to electronically submit Controlled Substances.
· Your facility begin using EPCS to electronically submit Discharge Orders to local pharmacies.
By implementing the above you facility will: enhance its security of Controlled Substances; streamline sending discharge orders to local pharmacies; and it will be ready for the March 26, 2017 deadline.
The RHS EPCS software features are installed, fully operational, and in live use. We look forward to implementing them at your facility. Please call us when you are ready.