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New California law creates e-prescribing exemption for dentists who meet specific criteria

Update: Board of Pharmacy's online prescriber registry is open

October 26, 2022 6144
Image of a computer keyboard with a glass container of pills on top. Some of the letter keys are readable.

Updated Jan. 6, 2023: The article confirms that the Board of Pharmacy's online prescriber registry is now open and includes a link to the exemption request form. The article also now includes a reminder that prescribers who receive an exemption from the e-prescribing requirement must use prescription forms printed by a state-approved security printer.

Dentists and other health care practitioners in California who issue 100 or fewer prescriptions in a calendar year could receive an exemption from the state’s existing law requiring practitioners to electronically prescribe all medications. 

But the exemption is not automatic. AB 852, supported by CDA and authored by Assemblymember Jim Wood (D-Santa Rosa), DDS, and signed into law late September by Gov. Gavin Newsom, requires prescribers meet designated criteria and take specified action.

The exemption is available to prescribers who register with the California State Board of Pharmacy and state that they meet one or more of the following:

  • They issue 100 or fewer prescriptions per calendar year.
  • Their practice is in the area of an emergency disaster declared by a federal, state or local government.
  • They are unable to issue electronic data transmission prescriptions due to circumstances beyond their control.

Prescriber registration with Board of Pharmacy is open

The Board of Pharmacy is responsible for creating the registration and on Jan. 4, 2023, announced the online registry was open. Qualifying prescribers can now complete and submit the exemption request form. Registration will be required annually with email reminders sent by the board to registered prescribers.

CDA supported AB 852 but cautions dentists who wish to be exempted from the electronic prescribing requirement to carefully evaluate and forecast their prescribing numbers to confidently determine they will fall below the threshold of 100 or fewer prescriptions per calendar year. Dentists should do this before they register with the Board of Pharmacy. Until successful registration with the board, and for all dentists who issue more than 100 prescriptions annually, electronic prescribing for all medications remains the law.

In addition to the online registry, the Board of Pharmacy created an online confirmation registry for verifying that a prescriber has registered for exemption from California's e-prescribing requirement.

A few other exemptions for the existing e-prescribing requirements already exist, such as due to a temporary service interruption or technological failure.

E-prescriptions submitted via noncompliant software can be declined

The new law also authorizes a pharmacy, pharmacist or other authorized practitioner to decline to dispense or furnish an electronic prescription submitted via software that fails to meet any one of specified criteria, including compliance with the federal Health Insurance Portability and Accountability Act of 1996.

Two CDA Endorsed Services, ePrescribe by Henry Schein One and iCoreRX from iCoreConnect, offer compliant electronic prescribing software with exclusive pricing for CDA members and assistance with installation. 

Members can also log in to their account to read CDA’s Prescribing and Dispensing Q&A for more details about the existing electronic prescribing requirement, exceptions to the state mandate and types of prescribing software. The resource also includes answers related to scope of practice and the use of CURES, the state’s prescription drug monitoring database, for prescribing controlled substances.

Prescription forms must meet state requirements

Dentists who have received an exemption from California's electronic prescribing mandate still must follow specific prescribing requirements, including using tamper-resistant prescription forms that are printed by a state-approved printer. A CDA article specifies all the required features of the paper prescription form and includes a link to the list of approved security prescription printers.  

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