December 10, 2021

Hardship Waivers for EPCS, PMP-EHR Integration Mandates

In 2019, the Washington State Legislature approved and Gov. Jay Inslee signed Senate Bill 5380, a measure aimed at curbing the opioid epidemic. Among the provisions outlined in the legislation are two IT mandates: a requirement that all prescriptions for controlled substances be transmitted electronically, and a requirement that practices with 10 or more prescribers integrate their electronic health records with the state prescription monitoring program. Both mandates take effect Jan. 1, 2022. WSMA successfully secured a hardship exemption for practices that are not able to comply with one or both of the mandates due to certain circumstances.

For the EPCS requirement, eligibility for an exemption includes economic hardship, technological limitations, and other exceptional circumstances. The Washington State Department of Health offers detailed information on eligibility. Eligible practices can attest to their hardship using the Electronic Prescribing Waiver Attestation Form.

For the PMP-EHR integration mandate, eligibility for an exemption includes economic hardship, technological limitations outside the control of the practice, other exception circumstances, and unforeseen circumstances (this includes widespread health care emergencies). More information on eligibility is available here. Please keep in mind that the PMP-EHR integration mandate is only applicable to practices with 10 or more prescribers. Eligible practices can attest to their hardship using the EHR/PMP Integration Waiver Attestation Form.

Attestations for both the EPCS and PMP-EHR integration mandates last for one year and may be renewed two times for a total of three waivers, except in the case of other exceptional circumstance waivers. Other exceptional circumstance waivers may be submitted an unlimited number of times. Beginning in December, each year you may submit a waiver for the following year. Waivers submitted part way through the year are valid for that calendar year and will not be prorated.

If you have questions about your eligibility for these hardship exemptions or the attestation waivers, email policy@wsma.org.