CMS Electronic Prescribing for Controlled Substances (EPCS) Program

Announcements

Measurement Year 2026 Resource Documents Now Available

The updated CMS EPCS Program resource documents for the 2026 measurement year are now available in the “Downloads” section.

Updated documents include:

Getting Started Quick Reference Guide
Requirements At-A-Glance
2025 Declared Disaster Fact Sheet

To receive notifications about future updated documents, subscribe to the CMS EPCS Program Listserv.

Available Now: Final Decisions for MY 2024 Submitted Waiver Applications

On the CMS EPCS Prescriber Portal, each non-compliant prescriber should be able to review the final decision for their submitted waiver application for measurement year (MY) 2024 of the Centers for Medicare & Medicaid Services (CMS) Electronic Prescribing for Controlled Substances (EPCS) Program.

Each non-compliant prescriber who submitted and received an approved waiver application now qualifies for a CMS-approved waiver exception for all of MY 2024, which means their final compliance status is compliant.

If a non-compliant prescriber’s waiver application was denied or didn’t go through the entire waiver application review process, this means they didn’t qualify for a CMS-approved waiver exception and, therefore, their final compliance status is non-compliant for MY 2024.

MY 2024 Compliance Analysis Period

CMS completed the program’s compliance analysis period for MY 2024, which began August 1, 2025, and ended September 15, 2025. During this time, CMS reviewed claims data for qualifying Schedule II–V controlled substance Part D prescriptions filled January 1–December 30, 2024, to determine whether prescribers met the compliance threshold for the CMS EPCS Program, after exceptions. To be considered compliant for MY 2024, prescribers must have electronically prescribed at least 70% of their qualifying Schedule II–V controlled substance prescriptions for patients covered under Medicare Part D, after exceptions, in the measurement year. For more details on how CMS determines program compliance, visit the “Compliance Overview” section.

MY 2024 Notification Period

The MY 2024 notification period began on September 16, 2025. At the beginning of this period, CMS released MY 2024 compliance information for prescribers, enabling prescribers and their designated representatives to access and review the compliance information on the CMS EPCS Prescriber Portal. The EPCS Prescriber Portal is a web platform that prescribers of Schedule II–V controlled substances under Medicare Part D and their designated representatives can access to:

Look up the prescriber’s compliance information and status for the measurement year
Submit a waiver application for the measurement year, if needed
Monitor the prescriber’s waiver application status

MY 2024 Non-Compliance Notice

As part of the MY 2024 notification period, CMS sent each prescriber identified by CMS as non-compliant with the program requirement for MY 2024 the non-compliance notice. The non-compliance notice included information to a prescriber that they were non-compliant with the program requirement, information about how they could come into compliance, information on the benefits of e-prescribing controlled substances, and a link to the EPCS Prescriber Portal where they could look up their initial compliance status and have the opportunity to submit a waiver application for circumstances beyond their control.

When possible, CMS emailed the non-compliance notice to non-compliant prescribers through CMSLists@subscriptions.cms.hhs.gov or EPCSProgramSupport@rainmakerssolutions.com. However, if a prescriber didn’t have an active email address in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or in the National Plan and Provider Enumeration System (NPPES), CMS sent the non-compliance notice as a physical letter.

For more information on the non-compliance notice, visit the “Non-Compliance Action” section.

MY 2024 Waiver Application Submission Period

The program’s waiver application submission period also started on September 16, 2025, and closed on November 18, 2025. During this period, each prescriber or their designated representative could log into the EPCS Prescriber Portal to look up the prescriber’s initial compliance status and submit a waiver application for circumstances beyond the prescriber’s control. CMS then determined each prescriber’s final compliance status for MY 2024, which was made available by late December 2025.

For more information on how to submit a waiver application, review the CMS EPCS Program Waiver Application Fact Sheet.

For more information on the EPCS Prescriber Portal and waiver application, review the CMS EPCS Prescriber Portal & Waiver Application User Guide and the CMS EPCS Program Waiver Application Fact Sheet (PDF).

Calendar Year 2025 Physician Fee Schedule Final Rule Changes for the CMS EPCS Program

On November 5, 2025, CMS published the Calendar Year (CY) 2026 Physician Fee Schedule (PFS) final rule. The final rule doesn’t include any updates to the CMS EPCS Program for measurement year (MY) 2026, which means that there also won’t be any updates to the EPCS Program for MY 2026. Updates to the EPCS Program requirement are introduced through rulemaking, so the program requirement for MY 2026 will be the same as for MY 2025.

For details on final rules from previous years, review the latest version of the EPCS Regulatory Milestones in the “Downloads” section.

Measurement Year 2025 Resource Documents Now Available

The updated CMS EPCS Program resource documents for the 2025 measurement year are now available in the “Downloads” section.

Updated documents include:

CMS EPCS Program Frequently Asked Questions
Getting Started Quick Reference Guide
Glossary
Regulatory Milestones
Requirements At-A-Glance
2024 Declared Disaster Fact Sheet

To receive notifications about future updated documents, subscribe to the CMS EPCS Program Listserv.

Measurement Year 2023 Compliance Status

For measurement year 2023, CMS sent informational notices to prescribers who met the program requirement only due to the declared national public health emergency. CMS sent the notices through email when possible and as a physical letter if there was no email address for the prescriber in the Provider Enrollment, Chain, and Ownership System (PECOS) or in the National Plan and Provider Enumeration System (NPPES).

CMS encourages prescribers to update their email and mailing addresses in PECOS and NPPES to ensure timely receipt of the notices and, therefore, the opportunity to submit a waiver application to become compliant. A prescriber’s non-compliance under the CMS EPCS Program may be considered in CMS processes for assessing potential fraud, waste, and abuse. Prescriber addresses are also used to determine who qualifies for the automatic declared disaster exception.

Prescribers who met the measurement year 2023 compliance only due to the declared national public health emergency had the option to submit a waiver request for additional extraordinary circumstances, such as technological limitations or other circumstances outside of their control.

The waiver application submission period was open from September 16, 2024, until Monday, November 18, 2024, at 8 p.m. ET.

For more on submitting a waiver application, see the CMS EPCS Program Waiver Application Fact Sheet.

CMS EPCS Policy in the Calendar Year 2025 Physician Fee Schedule Final Rule

CMS finalized the CMS EPCS Program policy that prescriptions written for a beneficiary in a long-term care (LTC) facility will not be included in determining compliance until January 1, 2028. CMS also finalized that compliance actions against prescribers who do not meet the compliance threshold based on prescriptions written for a beneficiary in an LTC facility will start measurement year 2028.

CMS EPCS Program Rules and Regulations

In October 2018, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) was enacted into Public Law (115-271) to address the opioid crisis. Section 2003 of the SUPPORT Act generally mandates that Schedule II–V controlled substances under Medicare Part D and Medicare Advantage prescription drug (MA-PD) plans be prescribed electronically in accordance with an electronic prescription drug program. The CMS EPCS Program is separate from State EPCS program requirements.

Electronic prescribing for controlled substances enhances patient safety through patient identity checks, medication recommendations, and timely and accurate transmission of time sensitive prescriptions. EPCS also reduces prescriber burden by deterring and detecting prescription fraud and irregularities, improving workflow efficiencies, avoiding data errors, and reducing pharmacy calls to clarify written prescriptions.

Section 2003 of the SUPPORT Act provides the Secretary of the Department of Health and Human Services with discretion on whether to grant waivers or exceptions to the CMS EPCS requirement and gives the Secretary the authority through rulemaking to enforce and specify appropriate penalties for non-compliance with the CMS EPCS Program requirement. In November 2025, CMS published the Calendar Year 2026 Physician Fee Schedule final rule. For information about previous final rules, please see the EPCS Regulatory Milestones document in the “Downloads” section.

CMS EPCS Program Timeline

The CMS EPCS Program timeline represents one measurement cycle, which is generally a 24-month period that consists of a measurement year, the compliance analysis period, and the notification period.

Figure 1. General Measurement Cycle

November before measurement year – Physician Fee Schedule Final Rule released
January 1 of measurement year – Compliance start date for measurement year
December 31 of measurement year – Compliance end date for measurement year
August after measurement year – CMS analysis of Part D prescription claims data for measurement year
September after measurement year – Non-compliance notices sent and prescriber compliance status available via CMS EPCS Prescriber Portal
September to November after measurement year – 60-day waiver application period for measurement year
November after measurement year – Prescriber notified of waiver approval or denial for measurement year

Compliance Overview

CMS EPCS Program Prescribers

Prescribers who issue prescriptions for Schedule II–V controlled substances to Medicare Part D beneficiaries from January 1 through December 31.

CMS EPCS Program Compliance Determination

CMS will analyze Medicare Part D Schedule II–V controlled substance prescription claims and use the prescriber’s National Provider Identifier (NPI) to measure compliance:

EPCS Compliance Rate (%) equals the number of electronically prescribed Part D schedule 2 through 5 controlled substance prescription claims from the prescriber, after exceptions, divided by the number of all Part D schedule 2 through 5 controlled substance prescription claims from the prescriber, after exceptions, multiplied by 100 percent.

If the EPCS compliance rate is 70% or higher, the prescriber is considered compliant.

CMS EPCS Program Exceptions

Small Prescriber Exception: CMS automatically provides this exception to prescribers who issue 100 or fewer qualifying Medicare Part D controlled substance prescriptions in the measurement year.
Declared Disaster Exception: CMS automatically provides this exception to prescribers located in the geographic area of an emergency or disaster declared by a Federal, State, or local government entity. Starting in the 2024 measurement year, CMS will identify which emergencies or disasters qualify for this exception. CMS posts a list of the qualifying emergencies or disasters for each measurement year in the “Downloads” section below.
CMS-Approved Waiver: CMS provides this exception to prescribers who submit and receive a CMS-approved waiver because the prescriber is unable to meet the CMS EPCS Program requirement due to circumstances beyond the prescriber's control.

Prescriptions written for a beneficiary in a long-term care (LTC) facility will be included in determining compliance no earlier than January 1, 2028.

Waiver Application

Prescribers or their representatives may submit a measurement year waiver application when circumstances beyond their control prevented them from electronically prescribing Schedule II–V controlled substances. Prescribers or their representatives have the opportunity to submit a waiver application in the CMS EPCS Prescriber Portal in the Fall after the measurement year (e.g., the 2024 measurement year waiver application period will start mid-September 2025).

Non-Compliance Action

As the non-compliance action for each measurement year, CMS will send non-compliance notices to prescribers who have not met the CMS EPCS Program requirement. The notice will include information to prescribers that they are violating the CMS EPCS Program requirement, information about how they can come into compliance, benefits of EPCS, and a link to the CMS EPCS Prescriber Portal where they can check compliance status and have the opportunity to submit a waiver application for circumstances beyond the prescriber’s control. A prescriber’s non-compliance under the CMS EPCS Program may be considered in CMS processes for assessing potential fraud, waste, and abuse, which, in some instances, could result in a referral to law enforcement or revocation of billing privileges, in the event that evidence of fraud, waste, or abuse is present. Notices will be sent by email, when possible, to available email addresses in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and in the National Plan and Provider Enumeration System (NPPES) and by physical mail if there is no email address in PECOS or NPPES. CMS strongly recommends that all prescribers keep their email address accurate and up to date in both systems.

Reminder: Keep Your Addresses Up to Date in PECOS and NPPES

CMS encourages prescribers to keep their email and mailing addresses up to date in PECOS and NPPES.

CMS uses these addresses and PECOS and NPPES as the data sources for identifying which prescribers qualify for the automatic declared disaster exception and for where to send prescribers the non-compliance notice.

Note that each year, updates made in PECOS and NPPES after mid-July after the measurement year might not be reflected in the CMS EPCS Prescriber Portal when prescriber compliance statuses become available in mid-September after the measurement year.

CMS EPCS Prescriber Portal

On the CMS EPCS Prescriber Portal, a prescriber of Medicare Part D Schedule II–V controlled substances and their designated representatives can check the prescriber’s compliance status and submit a waiver application for the measurement year. Users can log in to the CMS EPCS Prescriber Portal with their Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account user ID and password.

Once in the CMS EPCS Prescriber Portal, users can:

Review the prescriber’s compliance status for the measurement year, including any automatic exceptions
Submit a waiver application for the measurement year, if needed, based on circumstances beyond the prescriber’s control
Check the prescriber’s waiver application status

Although the prescriber’s compliance data for the measurement year won’t be available on the CMS EPCS Prescriber Portal until September of the following year (for example, MY 2024 data becomes available in mid-September 2025), CMS suggests that users take one of the following actions:

Reset their HARP account password. Registered users of the Quality Payment Program (QPP) should already have a HARP account. However, users may need to reset their HARP account password if they haven’t logged in to their account for 60 or more days.
Create a HARP account. Users who don’t have a HARP account will need to create one to log in to the EPCS Prescriber Portal.

For more information, review the CMS EPCS Prescriber Portal & Waiver Application User Guide.

To stay up to date on the CMS EPCS Prescriber Portal, subscribe to the CMS EPCS Program Listserv.

Go to the “Downloads” and "Related Links" sections for more resources.

Where Can I Get Help?

For additional help, reach out to the Center for Clinical Standards (CCSQ) Support Central:

By submitting an online ticket
Through emailing EPCS-EPrescribe@cms.hhs.gov
By calling 1-866-288-8292, Monday–Friday, 8 a.m.– 8 p.m. ET
By calling 711 to reach a telecommunications relay services communications assistant for those who are hearing impaired and for deaf individuals.
- For faster help, try calling outside peak hours, before 10 a.m. and after 2 p.m. ET.