CMS Electronic Prescribing for Controlled Substances (EPCS) Program

CMS EPCS Prescriber Portal

To view prescriber compliance status and apply for the measurement year waiver based on circumstances beyond the prescriber’s control, please visit the CMS EPCS Prescriber Portal at https://cqr.cms.gov/epcs/landing. Users can login with their HCQIS Access Roles and Profile (HARP) account credentials, please go to the “CMS EPCS Prescriber Portal Details” section below for more information.

Note: Compliance status and wavier application for the 2023 measurement year will be available in September 2024. 

CMS EPCS Rules and Regulation

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 Electronic Prescribing for Controlled Substances (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 noncompliance with the CMS EPCS requirement. In November 2023, CMS released the Calendar Year 2024 Physician Fee Schedule Final Rule. The final rule is available at: https://www.federalregister.gov/d/2023-24184. For information about previous final rules, please see the EPCS Regulatory Milestones document in the “Downloads” section below. 

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.

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

Example of 2023 Measurement Cycle

• November 18, 2022 – CY 2023 Physician Fee Schedule Final Rule released
• January 1, 2023 – Compliance start date for 2023 measurement year
• December 31, 2023 – Compliance end date for 2023 measurement year
• August 2024 – CMS analysis of Part D prescription claims data for 2023 measurement year 
• September 2024 – Non-compliance notices sent and prescriber information available via an EPCS Prescriber Portal
• September to November 2024 – 60-day waiver application period for 2023 measurement year
• November 2024 – Prescriber notified of waiver approval or denial for 2023 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: 

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, 2025. 

Waiver

Prescribers or their representatives may request a measurement year waiver when circumstances beyond their control prevented them from electronically prescribing Schedule II-V controlled substances. Prescribers or their representatives may request a waiver in the CMS EPCS Prescriber Portal in the Fall after the measurement year (e.g., the 2023 measurement year waiver application period will open September 2024).

Non-Compliance Action

As the non-compliance action for each measurement year, CMS will send non-compliance notices to prescribers who have not 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 a compliance, benefits of EPCS, and a link to the CMS EPCS Prescriber Portal where they can check compliance status and may request a waiver 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. Notices will be sent by e-mail, when possible, to available e-mail addresses in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and the National Plan and Provider Enumeration System (NPPES), and by regular mail if there is no e-mail address in PECOS or NPPES. CMS strongly recommends that all prescribers keep their e-mail address accurate and up to date in both systems.

CMS EPCS Prescriber Portal Details

Prescribers of Schedule II-V controlled substances under Medicare Part D or their designated representatives can log in to the CMS EPCS Prescriber Portal at https://cqr.cms.gov/epcs/landing. The portal is hosted on the Clinician Quality Reporting (CQR) website and users can login with their HCQIS Access Roles and Profile (HARP) account credentials. 

Once in the CMS EPCS Prescriber Portal, users can: 

• Review prescriber annual compliance status including the automatic exceptions, 
• Apply for the measurement year waiver based on circumstances beyond the prescriber’s control, and 
• Review waiver application status. 

While prescriber data for the measurement year will not be available in the portal until September in the following year (e.g., 2023 measurement year data available in September 2024), CMS suggests that CMS EPCS users take ONE of the following actions as soon as possible:

1. Reset Password: Those who are registered users of the Quality Payment Program (QPP) should already have a HARP account, however, a password reset may be required to access the CMS EPCS Prescriber Portal. Please note, your HARP account password will reset every 60 days if HARP is not accessed during that time.
2. Create Account: Those who do not already have a HARP account will be required to create one to access the CMS EPCS Prescriber Portal.

CMS encourages prescribers to subscribe to the EPCS listserv to stay up to date on the CMS EPCS Program. Click here to subscribe.

See Downloads and Related Links below for additional resources.