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How Will I-STOP Affect Specialty Prescribing?

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By Tony Schueth

New York’s I-STOP (Internet System for Tracking Over-Prescribing Act) went into effect on March 27.  The law requires that New York physicians use electronic prescribing (ePrescribing) for both non-controlled and almost all controlled substances (EPCS).

An area where ePrescribing will have a profound impact is on specialty pharmacy because today they are by and large not prescribed electronically for several reasons, primarily:

  • The prescriber often doesn’t know which pharmacy is part of a limited distribution or PBM network pharmacy.
  • The information necessary to dispense a specialty Rx is often not included in the ePrescription because the ePrescribing standard was created for the non-specialty retail and mail, oral solid paradigm that existed more than a decade ago.

[tweetthis]An area where #ePrescribing will have a profound impact is on #specialtypharmacy.[/tweetthis]

So, as national experts on ePrescribing, EPCS and medication management, we offer the following perspective on whether I-STOP requires specialty medications to be prescribed electronically:

Exemptions. There are three kinds of I-STOP exemptions, all of which could affect specialty, depending on the circumstances.

  • There are a handful of statutory exemptions listed in Article 2A, section 281, including if the prescription is from outside of New York state or cases of electrical or system failure.
  • A second exemption is a blanket waiver, which will be in effect for a year. Howard Zucker, New York’s Commissioner of Health, issued a letter on March 16 outlining a blanket waiver for a dozen exceptional circumstances regarding I-STOP. These include many compounded medications; those with a complex SIG; and controlled substances prescribed under public health and research auspices. Practitioners issuing prescriptions falling within the blanket waiver categories may either use the Official New York State Prescription Form or issue an oral prescription (subject to applicable restrictions and/or limitations). Pharmacists may dispense prescriptions issued on the Official New York State Prescription Form or oral prescriptions as covered under exceptional circumstances categories.
  • The third is an individual waiver. Some 2,300 doctors have received waivers from I-STOP requirements by sending extensive documentation (which must be completed annually) to the New York Department of Health.

Putting I-STOP into practice in specialty prescribing. The statute states that prescribers must transmit the prescription to the pharmacy electronically. Most specialty prescriptions go through a ‘hub,” which is a company that helps pharmacies and providers navigate the complex requirements of payers and others related to individual specialty pharmaceuticals, such as prior authorization (PA), co-pays and patient education. Because the hub isn’t a pharmacy, there isn’t any requirement that the prescription must go to the hub electronically.

As a matter of workflow, we envision that the prescription will go electronically from the prescriber to the pharmacy.  Since most specialty medications require PA, the pharmacy will be informed that PA is necessary. The physician’s office will either initiate the paperwork to the hub at the time that they are writing the prescription, or maybe at the time that the pharmacy alerts them that PA is required.

Once the hub does its work and the authorization is issued, the pharmacy dispenses the specialty medication. If a specialty pharmacy is not connected to Surescripts, the prescriber is eligible for an exemption because they are limited to a particular specialty pharmacy for a particular drug.

Other questions will arise as I-STOP rolls out.  We’d be happy to help. Write us or give us a call.

Tony Schueth

Tony Schueth

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