DEA and Prescription History

OpenEMR Development
1

mike-h30 wrote on Sunday, October 18, 2009:

Two DEA agents stopped by our office last week for a "5 year routine" visit.  They were impressed that we were electronic.  However, one of the agents mentioned that a copy of every prescription must be kept on file.

I noticed that OpenEMR only shows the last date a medication was prescribed.  I was curious if a feature request was in order to track prescription history so that one is able to view all medications prescribed and the dates they were prescribed in the patient chart?

-Mike

2

omo66 wrote on Thursday, October 22, 2009:

For now, I am saving those scripts into EMR after being created as PDF files. I was thinking on making this as an automatic process using Jason’s script for uploading documents into EMR folders.

Once I do this, I will share the code.

3

mike-h30 wrote on Thursday, October 22, 2009:

Omar,

Do you store a signed copy of your script in OpenEMR?  Or just the generated prescription PDF in the pop up window?

A previous EMR that we used ( Amazing Charts) would store each prescription and date prescribed in the patient chart.   I would prefer to avoid the overhead of having to scan and upload prescriptions when the data could be stored in a table.

-Mike

4

omo66 wrote on Thursday, October 22, 2009:

A faxed script will have a signture on it automatically.

Now also in version V3.1.0 you could print and gernerate a signed scripts and fax them on the fly.

You need to place a sig.png image of your signature inside interface/pic/sig.png.

Also make globals.php aware of this.

I had rarely to sign a script then scan and upload.

Omar

5

mike-h30 wrote on Thursday, October 22, 2009:

Sounds like a good idea.   I will give this a try.   However, I am wondering if pharmacies will accept this for controlled substances.

Thanks Omar.

P.S.  I would still like to have a history of scripts in a table withing the openemr db.

6

drpwayne wrote on Friday, October 23, 2009:

Mike,
Unless you are dispensing Schedule II narcotics in your practice, I don’t believe there is any requirement for maintaining copies of prescriptions. In NY State we used to have triplicate narcotic prescription pads and the state required us to keep our copy for 3 years, but about 2 years ago they switched to a system in which all prescriptions, narcotic and otherwise, are numbered and obtained through the state. The prescriptions do not come in triplicate and there is, to my knowledge, no requirement in the federal law for the prescriber to maintain a copy of the prescription.
I checked this with the actual federal law at the DOJ web site:

[Mike,
Unless you are dispensing Schedule II narcotics in your practice, I don’t believe there is any requirement for maintaining copies of prescriptions. In NY State we used to have triplicate narcotic prescription pads and the state required us to keep our copy for 3 years, but about 2 years ago they switched to a system in which all prescriptions, narcotic and otherwise, are numbered and obtained through the state. The prescriptions do not come in triplicate and there is, to my knowledge, no requirement in the federal law for the prescriber to maintain a copy of the prescription.
I checked this with the actual federal law at the DOJ web site:

http://www.usdoj.gov/dea/pubs/csa/829.htm#a

Did the DEA agents give you some justification for that statement?
- Peter

 

7

markleeds wrote on Friday, October 23, 2009:

Mike,

If you are dispensing, I believe you would need the original prescription, not a copy.  For controlled substances, a prescription still must be written even if you dispense it in your own office.

Assuming your office is not dispensing, it sounds like you need to be able to generate a prescription history for a given patient.  How are you currently producing your prescriptions?  Does OpenEMR keep each individual prescription in the database and you just  need a custom report to list them?  As you know, I enter and print my prescriptions from CAMOS and I can use a custom report to easily generate such a list.  I don’t know if the built in prescription module saves this information.  If it does, I can help you write the report code.

Mark

8

mike-h30 wrote on Friday, October 23, 2009:

Peter,

The DEA agent mentioned that when prescribing narcotics and Suboxone (we are a pain management practice and prescribe both) a record needs to be kept on file for every script.   OpenEMR does not track this.

Mark,

That is correct - we are not dispensing in our office.  We are writing prescriptions with the built in prescription module.  Unfortunately, the "prescriptions" table only stores unique medications with "start date" and "date modified".   This is not an acceptable way of tracking narcotics and Suboxone prescriptions according to the DEA agents that stopped by.  We may have to switch our prescription writing to CAMOS to be in compliance with DEA recommendations for prescribing narcotics and Suboxone.

Also, my concern with switching scripts to CAMOS is how it would handle multiple users.  The last thing I want is to have a non-physician provider ( i.e. a physical therapist) have access to the physician medications template.

-Mike

P.S. Is prescription history something that will need to be addressed for CCHIT?

9

n757 wrote on Thursday, November 19, 2009:

All,

Prescribing in NY is tightly controlled.  Laws are MORE restrictive than federal.

Official forms must be used.  I believe they can be ordered 4 to a letter-sized page as well as in pad format.  Each has a control number.

All prescriptions, Sched II or not,  must have a handwritten signature - signature cannot be preprinted or computer generated.

Quantity and number of refills must be written in words as well as numbers.

Patient address cannot be a PO box.

http://www.health.state.ny.us/professionals/narcotic/practitioners/newsletters/docs/practitioner_udpate_spring_2009.pdf

When Sched II drugs are  dispensed, whoever dispenses is required to transmit data to the state, which includes the control number.

The state monitors the data and compares it with drug sales to the dispensing facilities; they also try to detect patients getting the same Sched II drug from more than one practitioner.  They may expect to be able to go to a practitioner and find the matching prescriptions as well.  

The prescription form in NY will be changing soon (again).

Questions:

Does OpenEMR 3.1.0 satisfy federal requirements?

Since each state seems to have their own requirements, which are becoming more restrictive over time, and may be more restrictive than federal, including preprinted forms that must be used and change frequently, what is the best way to handle this in OpenEMR?

Right now, it seems that the output format is buried in code, in the prescription object class.  Is this the best place? 

Could there be a base prescription class, extended for each state, and for available state output formats?

Base class
Base output format 1 up
NY class
NY format 1 up
NY format 4 up
FL class
FL format 1 up
etc.

What’s the best way to structure modifications to the forms, eg base form, NY form, FL form….?

And best way to configure?

Joanne

10

n757 wrote on Thursday, November 19, 2009:

Correction:  output format is buried in constructor C_Prescription.class.php. 

Configuration of a sort is in includes/config.php.