EPS and Controlled Drugs
EPS and Controlled Drugs
NHS Digital is preparing to pilot the prescribing and dispensing of EPS Schedule 2/3 Controlled Drugs (CDs). Initially around 10 GP practices will gain the ability to prescribe CDs. The project aims to demonstrate that EPS CD prescribing capability can be more widely unrolled. Instalment dispensing via EPS is not yet possible. Prescribers remain free to continue to issue paper prescriptions.
EPS Controlled Drugs dispensing / pilot
NHS Digital is preparing to pilot the prescribing and dispensing of EPS Schedule 2/3 Controlled Drugs (CDs). Initially up to 15 GP practices will gain the ability to prescribe CDs. The project aims to demonstrate that EPS CD prescribing capability can be more widely unrolled.
The first pilot GP practices will be some of those using the Vision and EMIS GP system in the North and London. However, because patients can get their prescriptions dispensed from any community pharmacy in the country, pharmacy teams outside of these areas should also follow developments. Pharmacies nearby pilot GP practices will be notified ahead of the pilot.
EPS instalment dispensing will be out of scope. GP practices have also been informed they should not prescribe oral liquid methadone via EPS. Not all pharmacy system suppliers have enabled the PD endorsement yet.
Feedback from GP practices, community pharmacies, PSNC and other stakeholders will be used to refine the process for further roll-out.
EPS CD dispensing during the pilot phase
Standard Operating Procedures (SOPs) may be amended to reflect that Schedule 2 and 3 CDs could be prescribed by EPS as well as by FP10 paper. There will be no changes to the process of Instalment Dispensing on paper FP10MDA forms.
Key changes to consider include:
- CDs and non-CDs could arrive on the same EPS prescription and any processes that rely on CDs being handled in isolation may need to be changed.
- Best practice guidance to capture the details of the person collecting the CD prescription remains in place: an EPS dispensing token (FP10DT) can be used for this purpose and such tokens can be sent to the Pricing Authority.
- A method of “marking” the prescription “at the time of supply” should be decided to ensure compliance with the Misuse of Drug Regulations. The dispense notification may be suitable for this, but depending on local system configuration another patient medication record (PMR) process that records a date and leaves an electronic audit trail may be more suitable. Physically marking the EPS dispensing token (FP10DT) is not a suitable method as this is not the legal prescription.
Regulatory and technical background
Changes in legislation
From 1 July 2015, legislation came into force allowing Schedule 2 and 3 controlled drugs to be prescribed and dispensed using the electronic prescription service (EPS) release 2 messages.
EPS release 2 prescriptions for Schedule 2 and 3 controlled drugs will need to satisfy the usual prescription writing requirements (see below) including the need to express the total quantity in words and figures. In PSNC’s response to the consultation on allowing Schedule 2 and 3 controlled drugs to be prescribed via EPS we suggested that this requirement should not apply to electronic prescriptions, but the Home Office concluded that the requirement should remain.
The NHS Digital has issued all GP and community pharmacy system suppliers with the technical requirements to implement Controlled Drugs prescribing via EPS. All dispensing systems must be updated and fully deployed across all pharmacy sites, before it is possible to enable the new functionality. This is to avoid the possible risk of a prescriber sending a prescription for a controlled drug to a pharmacy which can’t then dispense it.
GP system ‘tactical fix’ to include words and figures
The change in legislation to allow CDs to be sent via EPS included the requirement for the quantity in words to be included in the electronic prescription; NHS Digital said in May 2016 that the anticipated timescale for all pharmacy system suppliers to develop this functionality may be as late as December 2018. Due to these extended timescales, a new tactical fix has been developed by NHS Digital which will not require the pharmacy system suppliers to upgrade their systems immediately, instead the fix would rely on the prescribing system suppliers. The tactical fix will be to put the quantity in words into the additional instructions field of the EPS message. A notification has now been submitted to the prescribing suppliers about the need for this fix, and when they are able to make the necessary changes, NHS Digital assurance will take place, with the aim to make the functionality available as soon as possible.
Q. Can a prescriber issue an FP10MDA Instalment Dispensing prescription electronically via the Electronic Prescription Service?
A. In England, only Schedule 2 Controlled Drugs plus Buprenorphine, Buprenorphine/Naloxone (Suboxone) and Diazepam can be prescribed in instalments on Form FP10MDA.
Schedule 2 and 3 Controlled Drugs may be dispensed when prescribed using the Electronic Prescription Service from 1 July 2015 (although technical amendments to prescribing and pharmacy systems are likely to delay the implementation of this change). However, there is currently no equivalent to FP10MDA in the electronic prescription service, so prescribers wanting supplies to be made in instalments will need to continue to use hard copy FP10MDA forms.
Q. What if I receive an EPS prescription for oral liquid methadone?
Pilot GP practices with EPS CD capability have been informed they should not prescribe oral liquid methadone via EPS. If this item is prescribed inadvertently the prescriber might be asked by the pharmacy contractor to arrange for a paper prescription.
Note that whilst oral liquid methadone prescriptions can be claimed/reimbursed, not all pharmacy system suppliers have yet enabled the PD endorsement, therefore either standard paper FP10 or paper FP10 MDA may be appropriate instead.
Q. What if I dispense an EPS CD for a patient on the end of the 28th day but I sent the dispense notification on the 29th day? Can I still be reimbursed?
The pharmacy system supplier ought not to put in place unnecessary blocks preventing you sending Dispense and Claim messages even after the 28 days for CDs because the real-life dispensing could have taken place within 28 days.
If your system supplier put in place unnecessary blocks to prevent you being paid fairly to cover cost of medicine, you may choose to request to your system supplier that such blocks are removed. Pharmacy system suppliers might choose to issue pop-up messages and guidance rather than any blocks.
Q. What is the status with the roll-out of EPS CD pilots across different GP system user bases?
|GP system||Status with roll-out|
|Vision (InPS) GP system||Limited pilot planned soon – less than ten GP practices to initially test EPS CDs in North and London|
|EMIS Web (EMIS Health) GP system||Limited pilot planned soon – less than ten GP practices to initially test EPS CDs in North and London|
|Evolution (Microtest)||Pilot expected in future|
|SystmOne (TPP)||Pilot expected in future|
- What items can be covered by EPS
- Dispensing controlled drugs
- Controlled Drug regulations
- System supplier preparedness for EPS CDs (NHS Digital pdf)