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Tag: Law

  • E-Prescribing Required in California

    E-Prescribing Required in California

    Effective as of January 1, 2022, health care practitioners submitting prescriptions to pharmacies must do so electronically. Passed into law in 2018, assembly bill #2789 also has provisions for pharmacies handling prescriptions, with penalties for noncompliance including referral to state licensing boards for sanction. The E-Prescribing rules apply for controlled and non-controlled substances. There are a number of exemptions. We would encourage you to read the bill and seek assistance if you have specific questions:

    https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=20…

    The good news is that many Electronic Health Records systems have built-in or compatible E-prescribing components. Additionally, the benefits of E-prescribing include faster transmission, easier access for patients, and reduced opportunity for misuse.

  • What is PAVE, Sign Up Now

    What is PAVE, Sign Up Now

    Beginning July 1, 2021*, providers who service the Medi-Cal population will be required to use the PAVE system when submitting new applications or when making certain changes to an existing application (eg. adding a location). For various reasons, even when not creating or changing a Medi-Cal Provider application, all of the provider types listed below should enroll in the PAVE portal before this date.

    Background and Acronyms

    PAVE stands for Provider Application and Validation for Enrollment system. PAVE is administered by the Provider Enrollment Division (PED) of the Department of Health Care Services (DHCS). Providers billing Medi-Cal for services must have an approved application with PED. PAVE replaces the paper application process with an online portal designed to improve the speed and efficiency of the application process for providers while providing DHCS with new tools to evaluate and periodically reassess the providers servicing the Medi-Cal population.

    Ultimately, the move to PAVE is designed to improve the quality of, and access to, care for patients with Medi-Cal, while ostensibly making the application process easier for providers.

    Psychiatrists and Prescribers will enroll using the Ordering/Referring/Prescribing Only Provider category.

    Sign up Now

    Information about the PAVE system including deadlines and eligibility is plentiful but often contradictory. We reviewed several sources (linked below) and spoke with a customer representative to compile this information.

    From our perspective there are at least three benefits to using PAVE for providers.

    FIRST, the application is potentially faster. By entering an NPI number with a Medi-Cal PIN (or other identification) the system will automatically sync existing Medi-Cal provider information with your PAVE Business Profile. More about Profiles and Users in benefit #3.

    SECOND, status notifications including approval and requests for corrections or additional information should be available much quicker and accessible directly from the PAVE system.

    THIRD, the PAVE system allows providers to delegate management of the provider’s Business Profile to additional Users in the PAVE system. PAVE User accounts are how an individual logs into PAVE. A PAVE Business Profile is the provider entity with approval to bill Medi-Cal. You log in with your User account in order to make changes to a Business Profile, and if you are a busy provider you can delegate this to another individual with PAVE access. This could significantly reduce the administrative burden on some providers.

    But Wait, There’s More!

    After enrolling in PAVE your next task is to register in the Medi-Cal Rx Provider Web Portal, more on that another time. Below you will find two lists: types of providers required to use PAVE and links to additional information including the Medi-Cal Rx Provider Web Portal.

    REQUIRED MEDI-CAL PROVIDERS

    • Licensed clinical social workers
    • Licensed Marriage and Family Therapists
    • Licensed Professional Clinical Counselors
    • Licensed Psychologists
    • Nurse Practitioners
    • Occupational Therapists
    • Medical Doctors and Osteopaths (DO)
    • Physician Assistants
    • Registered pharmacists, pharmacists
    • Speech Therapists

    “Any discipline not listed above does not need to enroll in PAVE. This includes but is not limited to Psychiatric Technicians, Clinical Nurse Specialists, and Registered Nurses. Students and trainees do not need to enroll in the PAVE System.” (From Quality Assurance Bulletin, link #5 below)

    A list of supported provider types can be found here:
    https://www.dhcs.ca.gov/provgovpart/Documents/PAVE_Project_for_Provider_…

    LINKS AND REFERENCES

    1. PAVE Login: https://www.dhcs.ca.gov/provgovpart/Pages/PAVE.aspx
    2. PAVE FAQs: https://www.dhcs.ca.gov/provgovpart/Documents/PAVE_Project_for_Provider_…
    3. SMHS FAQs: https://www.dhcs.ca.gov/provgovpart/Documents/PAVE_Project_for_Provider_…
    4. PAVE Training Videos: https://www.dhcs.ca.gov/provgovpart/Pages/PAVEProviderTrainingVideos.aspx
    5. LA County QA Bulletin: http://file.lacounty.gov/SDSInter/dmh/1081140_20-07PAVEMediCalRxPortal.pdf
    6. LA DMH PAVE FAQs: http://file.lacounty.gov/SDSInter/dmh/1081141_PAVEFAQs.pdf
    7. Medi-Cal Rx: https://medi-calrx.dhcs.ca.gov/home/

    *this is the most up-to-date information we can find.

  • Understanding Your Responsibilities in the California CURES 2.0 Program

    Understanding Your Responsibilities in the California CURES 2.0 Program

    The Controlled Substance Utilization Review and Evaluation System, also known as CURES 2.0, comes from California’s Health and Safety Code Section 11165.1.

    Effective Oct 2, 2018, all doctors, prescribing schedule II, III and IV to patients for the first time must consult the CURES system no earlier than 24 hours before prescribing (or the previous business day). They are also required to check the CURES system at least once every 4 months thereafter if the controlled substance remains part of the treatment plan of the patient.

    Doctors, if you don’t already have a login, you can register at this link.

    Potential Impact on Mental Health Organizations

    Organizations that provide medication support services may want to be prepared for a number of changes. These are among the things we think you will want to consider and prepare for:

    • Allocate more time for initial medication evaluations and for medication follow ups, as all doctors will need to check the CURES database when they prescribe a controlled substance.
    • The doctor will also need to check the CURES database prior to prescribing each/any new controlled substance medication.
    • A system may need to be implemented that flags the patient’s chart or set a reminder for the doctors to check the CURES database every 4 months for those patients taking controlled substances. This will need to occur for as long as the patients are taking the same controlled substance as part of their treatment plan.
    • Doctors covering for other doctors prescribing or providing a refill of a controlled substance, will have to check the CURES database as it will count as their first time prescribing a controlled substance to that patient.
    • For potential auditing purposes, it is highly recommended that the prescriber document the CURES database check in the patient’s chart, or place the Patient Activity Report (PAR) from the CURES database in the patient’s chart.
    • Only the prescribing doctor can check the CURES database when prescribing a controlled substance. Support staff can be identified as “Delegates” by the prescribing doctor, but they can only request the PAR for the prescribing doctor to review. The report will be posted to the prescribing doctor’s dashboard where only she/he will be able to view it and print.
    • The CURES requirement also applies to out-of-state doctors providing telemedicine/telepsychiatry services to patients living in California.

    Exemptions

    There are exemptions to this requirement, including certain treatment settings and emergency scenarios. If you think you may qualify for an exemption, we suggest that you first get confirmation from the California Department of Justice. However, our recommendation would be to always check the CURES database as part of your risk management practices.

    Be Prepared

    To better understand the CURES program and its effects, we reviewed a number publications and spoke by phone to representatives at the California Department of Justice and the California Medical Board. Please be aware that your practice or organization may be impacted differently.

    Additional Information

    California Medical Board CURES FAQ
    California DOJ CURES FAQ
    California Hospital Association on CURES