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 has begun to pilot the prescribing and dispensing of EPS Schedule 2 and 3 Controlled Drugs (CDs) in England. From early October 2018, ten GP practices initially were granted ability to prescribe CDs with the project aiming to demonstrate that EPS CD prescribing capability is safe and appropriate to be rolled out more widely.

The first pilot GP practices were some of those using the Vision and EMIS GP systems in the North and London. However, because patients can get their prescriptions dispensed from any community pharmacy in the country, community pharmacy teams outside of these areas should also take note of these developments. Pharmacies near the pilot GP practices were notified ahead of time. SystmOne prescribing system begun piloting the prescribing of Controlled Drugs (CDs) via EPS during early 2019. The practices are in Newcastle, South Yorkshire and Southend-on-Sea.

EPS instalment dispensing (FP10MDA forms) won’t be possible because this requires additional changes to be made to EPS to support this. Because not all dispensing systems are able to endorse electronic prescriptions for oral liquid methadone with a packaged dose endorsement (PDn), a paper FP10 prescription will still need to be generated for this medicine. Prescribers are being asked not to prescribe oral liquid methadone using EPS.

Feedback from GP practices, community pharmacies, PSNC and other stakeholders will be used to refine the process prior to further roll-out. If the pilot is successful, EPS will be deployed to further and all Vision / EMIS / SystmOne  sites. Other GP system suppliers are developing CD prescribing capability and NHS Digital will manage the deployment on a supplier-by-supplier basis. Further details on that will be provided in due course.

Feedback from GP practices, community pharmacies, PSNC and other stakeholders will be used to refine the process for further roll-out.

If you receive an EPS Controlled Drug and have any comments, issues, or tips that support efficient dispensing, please contact info@psnc.org.uk or PSNC Community Pharmacy IT Lead, Daniel Ah-Thion.

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:

  1. 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.
  2. 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.
  3. 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.

Pregabalin & gabapentin – prescribing by EMIS GP practices from February 2019

Changes to general practice clinical systems will have to be made ahead of 1st April 2019, when pregabalin and gabapentin will be classified as Schedule 3 Controlled Drugs (CDs); see below for more information on this change.

PSNC has been informed by NHS England that the EMIS general practice clinical system has started to make this change at GP practices and the software in all EMIS practices will be updated by 15th February 2019. Once the software is updated, repeat prescriptions for pregabalin and gabapentin which have previously been issued as EPS scripts, will revert to being issued via paper FP10 prescriptions.On 12th February 2019, NHS England issued the following briefing note on Rescheduling of Gabapentin and Pregabalin as Schedule 3 Controlled Drugs.

Implications for pharmacy teams – if a local GP practice uses the EMIS clinical system, once their software has been updated, prescriptions for pregabalin and gabapentin will be issued as paper FP10s not EPS prescriptions.

If a patient’s other prescription items are issued via EPS, there is a risk that the paper script for pregabalin or gabapentin may not be collected from the GP practice; pharmacy teams should be alert to this risk and should advise patients that the paper script will need to be collected from the practice (or the pharmacy could offer to collect the script for the patient if you provide a prescription collection service).

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.

Technical changes

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.

Pilot FAQs

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 form.

Q. If I dispense a medicine an EPS CD within the appropriate interval (e.g. 28 days) but do not send the EPS message later (e.g. because of a technical outage) can I still claim for the prescription?

Most PMR suppliers reported to PSNC that they opted not to insert a barrier that would prevent reimbursement (although the technical EPS 180 expiry will still apply). In case of any PMR suppliers opting in future to prevent EPS dispense or claim notifications being sent after the 28-day prescription expiry, where drugs are dispensed within the 28 days we recommend sending claim messages promptly to avoid loss in payment. Read more at prescription validity periods. Some PMR systems may provide pop-up messages warning you if the appropriate interval has passed.

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 Piloting first begun for EPS CDs in North and London. Upon successful piloting EPS CDs will be expanded to further and all practices using EMIS.
EMIS Web (EMIS Health) GP system Piloting begun for EPS CDs in North and London. Upon successful piloting EPS CDs will be expanded to further and all practices using EMIS.
Evolution (Microtest) Pilot expected in future
SystmOne (TPP) Piloting begun for EPS CDs in Newcastle, South Yorkshire and Southend-on-Sea. Upon successful piloting EPS CDs will be expanded to further and all practices using EMIS.

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