EPS and Controlled Drugs

EPS and Controlled Drugs

National roll-out for EPS CDs is currently underway for three GP systems: Vision / EMIS / SystmOne. Community pharmacy teams may find it useful to refer to NHS Digital’s schedule to identify when their local GP practices are due to go live.

Read PSNC’s EPS CDs FAQs factsheet (published March 2019)

EPS Controlled Drugs national roll-out

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.

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.  NHS Digital is working with EMIS to confirm national roll out plans for EMIS Web users and announcements may come shortly.

If you receive an EPS Controlled Drug and have any comments, issues, or tips that support efficient dispensing, please contact PSNC Community Pharmacy IT Lead, Daniel Ah-Thion. The usual EPS escalation routes will also apply for formally raising any EPS questions or issues.

EPS CD dispensing during the early roll-out 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.

EPS Controlled Drugs pilots (2018-2019)

NHS Digital began 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 were in Newcastle, South Yorkshire and Southend-on-Sea.

National rollout plans were announced (see section above). Piloting for those GP practices using Microtest is to be announced.

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.

NHS Digital is working with EMIS to confirm national roll out plans for EMIS Web users.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.

FAQs

Read PSNC’s EPS CDs one-pager factsheet

Q. Are ‘words and figures’ required on my PMR screen for paper Release 1 prescriptions?
Words and figures are required on the legal prescription, which in the case of Release 1 barcoded prescriptions is the piece of paper. Some PMR systems may opt to also show words on the PMR screen but there is not a legal requirement that this information needs to be there.

Q. Can a prescriber issue an FP10MDA Instalment Dispensing prescription electronicallyusing EPS?

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 EPS. However, there is currently no equivalent to FP10MDA for EPS. Prescribers wanting supplies to be made in instalments will continue to use hard copy FP10MDA form.

Q. Do the dispense and claim notification messages for a Schedule 2 or 3 CD prescribed using EPS need to be submitted within 28 days of the date on the prescription?

Legally, all Schedule 2 and 3 CDs must be dispensed within 28 days of the appropriate date. However, for the purposes of claiming reimbursement, pharmacy systems should allow you to send the dispense and claim notification messages after the validity period of 28 days as it is recognised that scenarios may exist (e.g technical outages) where it may not be possible to submit a claim before the 28 days even though medicines were supplied within 28 days.

Your system supplier may alert you to any CD prescriptions yet to be dispensed and approaching their end of validity period of 28-days. Further information is available on our Period of validity webpage.

Q. What if I receive an EPS prescription for oral liquid methadone?

GP practices 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. Do the dispense and claim notification messages for a Schedule 2 or 3 CD prescribed using EPS need to be submitted within 28 days of the date on the prescription?

Legally, all Schedule 2 and 3 CDs must be dispensed within 28 days of the appropriate date. However, for the purposes of claiming reimbursement, pharmacy systems should allow you to send the dispense and claim notification messages after the validity period of 28 days as it is recognised that scenarios may exist (e.g technical/internet outages) where it may not be possible to submit a claim before the 28 days even though medicines were supplied within 28 days.

Your system supplier may alert you to any CD prescriptions yet to be dispensed and approaching their 28-day expiry. Further information is available on our Period of validity webpage.

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 Nationally rolled out
EMIS Web (EMIS Health) GP system National rollout scheduled to occur by 8th April 2019
Evolution (Microtest) Pilot expected in future
SystmOne (TPP) Nationally rolled out

Feedback

If you receive an EPS Controlled Drug and have any comments, issues, or tips that support efficient dispensing, please contact PSNC Community Pharmacy IT Lead, Daniel Ah-Thion. The usual EPS escalation routes will also apply for formally raising any EPS questions or issues.

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