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E-Prescribing Exemptions for Compounded Prescription Formulations
E-Prescribing Exemptions Regarding COMPOUNDED PRESCRIPTION FORMULATIONS
Courtesy of Healthway Compounding Pharmacy
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UPDATE! Mandatory E-Prescribing Enforcement Delayed Until 2023 FAQ's 12.6.21
State of Michigan | Act No. 134 Public Acts of 2020 Enrolled House Bill No. 4217 Approved by the Governor
July 8, 2020
Sec. 17754a (Click HERE to read the entire Public Act)
5) The requirement to transmit a prescription electronically under subsection (1) does not apply under any of the following circumstances:
a) If the prescription is issued by a prescriber who is a veterinarian licensed under this article. b) If the prescription is issued under a circumstance in which electronic transmission is not available due to a temporary technological or electrical failure. c) If the prescription is issued by a prescriber who has received a waiver from the department under subsection (7). d) If the prescription is issued by a prescriber who reasonably believes that electronically transmitting the prescription would make it impractical for the patient who is the subject of the prescription to obtain the prescription drug in a timely manner and that the delay would adversely affect the patient’s medical condition. A prescriber who does not electronically transmit a prescription under this subdivision shall document the specific reason for his or her belief that the delay would adversely affect the patient’s medical condition. e) If the prescription is orally prescribed under section 7333 (3) or (4). f) If the prescription is issued by a prescriber to be dispensed outside of this state. g) If the prescription is issued by a prescriber who is located outside of this state to be dispensed by a pharmacy located inside of this state. h) If the prescription is issued and dispensed in the same health care facility and the individual for whom the prescription is issued uses the drug exclusively in the health care facility. As used in this subdivision, “health care facility” includes, but is not limited to, any of the following: i) A hospital. ii) A hospice. iii) A dialysis treatment clinic. iv) A freestanding surgical outpatient facility. v) A skilled nursing facility. vi A long-term care facility that provides rehabilitative, restorative, or ongoing skilled nursing care to an individual who is in need of assistance with activities of daily living. 10 The Bulletin | December 2021
i) If the prescription contains content that is not supported by the National Council for Prescription Drug Programs Prescriber/Pharmacist Interface SCRIPT Standard. j) If the prescription is for a drug for which the FDA requires the prescription to contain content that cannot be transmitted electronically.
k) If the prescription is issued under circumstances in which the prescriber is not required to include on the prescription a name of a patient for whom the prescription is issued including, but not limited to, a prescription issued under section 5110. l) If the prescription is issued by a prescriber who is prescribing the drug under a research protocol.
SUMMARY
Compound (Custom) Formulations are a defined exemption from the 2022 e-script requirements because Compound (Custom) Formulations are not included as a part of the National Script Standard Interface referenced in Public Act 134 of 2020. Currently, a prescriber cannot send an electronic prescription for a Compound (Custom) Formulation in the same manner as a manufactured medication to Retail Pharmacy. This is because the Compound (Custom) Formulation does not match with the medications listed in the National Script Standard Interface being used to electronically transmit prescriptions. There are non-traditional ways to send a prescription electronically (e-script) for a Compound (Custom) Formulation to a Compounding Pharmacy. If any prescriber needs information or assistance with an e-script for a compound, they can call us at (989) 791-1961, option #2.
Because Compound (Custom) Formulations are exempt from the 2022 e-script regulatory requirements, prescribers still have multiple prescribing options with Healthway Compounding Pharmacy: Phone (989) 791-1691 | Fax (989) 791-4603 Bring in a paper prescription
Questions? Contact our Compounding Pharmacists, Mike Collins or Eddie Wright at (989) 791-1691, option #2
Contact: Larry Greene | Healthway Compounding Pharmacy 2544 McLeod Drive N. | Saginaw, MI 48604 Phone (989) 791-1691 | Fax (989) 791-4603 Healthwayrx.com
SECOND READING: Applications for membership for second reading and vote for approval at the January 18, 2022, Board Meeting:
Michael J. Mishkin, DO
(Ascension St. Mary’s Riverfront Cardiology/MCVI) Specialty: Cardiovascular Disease - Board Certified 2015 Medical School: Nova Southeastern University College of Osteopathic Medicine, Fort Lauderdale, FL, 2008 Internship: Largo Medical Center, Largo, FL, Traditional, 6/08-6/09 Residency: University of South Florida, Tampa, FL, Internal Medicine, 7/09-6/12 Fellowship: University of South Florida, Cardiovascular Medicine, 7/12-7/15 Sponsors: Doctors Sarosh Anwar and Vipin Khetarpal
Anirudh V. Penumetcha, DO
(Ascension St. Mary’s Riverfront Cardiology/MCVI) Specialty: Non-Invasive Cardiology - Board Certified 2021 Medical School: Michigan State University College of Osteopathic Medicine, 2015 Internship/Residency: Wayne State University, Detroit Medical Center, Internal Medicine 7/15-6/18 Fellowship: Wayne State University, Cardiovascular Disease, 7/18-6/21 Sponsors: Doctors Sarosh Anwar and Vipin Khetarpal
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