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Washington News: Electronically Transmitted Prescriptions
Published in the October 2006 Washington State Board of Pharmacy Newsletter
How are you doing with technology today? Electronic prescription issues seem to be on everybody’s agenda. The federal government is actively promoting electronic prescription system standards through the Medicare Prescription Drug, Improvement, and Modernization Act of 2003. In addition, they are providing free electronic records systems to doctors and are prodding Drug Enforcement Administration (DEA) to develop an electronic system standard for controlled substance (CS) prescriptions.
The Board of Pharmacy receives many applications from vendors of electronic prescription transmission systems and a stream of questions from you, who are providing care.
The same electronic prescription transmission systems that provide improved patient safety and a vast number of efficiencies also bring more complexities to the work. Test your knowledge of electronically transmitted prescriptions by answering the following questions.
Q: Where is a list of Board-approved electronic prescription systems?
A: The Board of Pharmacy maintains a list of approved systems on the Board’s Web site. The law, Revised Code of Washington (RCW) 69.41.055, and rules, Washington Administrative Code (WAC) 246-870, are also available on the Web site. The rules contain detailed information on electronically transmitted prescriptions.
Q: Does an electronic prescription in Washington State require two signature lines at the bottom?
A: No. Washington law, RCW 69.41.055, states an electronic prescription must provide an “explicit opportunity” indicating whether or not a therapeutically equivalent generic may be substituted. Various methods can be used to communicate on the prescription whether or not a generic may be substituted. Boxes, checks, and other indicators can be used. We frequently receive complaints from pharmacies that the electronic prescription does not contain this information. Occasionally we learn that a Board-approved system has been altered by the purchaser of the software or a practitioner is using an unapproved out-of-state version. If you receive a prescription that does not comply with the Board’s rules, please contact the Board office so we can work with the vendor or practitioner to bring the program into compliance with the law.
Q: Can an electronic signature (e-signature) on an electronic prescription look just like the prescriber name in typed characters?
A: Yes. The Electronic Signatures in Global and National Commerce Act defines an e-signature as any “electronic sound, symbol, or process attached to the record by a person with the intent to sign the record.” This makes the electronic document equivalent to a paper document, and it can be offered as evidence under the same rules of admissibility as a hand-signed document. Some electronic prescription systems take this approach, while many incorporate the actual signature.
Q: Must I call on every electronically transmitted Schedule III and Schedule IV prescription?
A: No. DEA states that pharmacists who receive electronically transmitted prescriptions have a liability to ensure the validity of the prescription as if it were an oral prescription. DEA has not mandated the method a pharmacist must use to ensure the validity of the prescription; however, many pharmacists interpret the requirement as requiring a call to the prescriber. The Board supports DEA’s policy on pharmacist verification of electronic Schedule III-V prescriptions and encourages pharmacists to use their professional judgment, dispensing procedures and controls, and common sense to evaluate each prescription. Pharmacists should never hesitate to contact the prescriber for verification or clarification.
