CMS Electronic Prescribing for Controlled Substances (EPCS) Program

CMS Electronic Prescribing for Controlled Substances (EPCS) Program

Announcements

Access Now: MY 2025 Compliance Information on the CMS EPCS Prescriber Portal

Prescribers may now review their measurement year (MY) 2025 compliance information for the Centers for Medicare & Medicaid Services (CMS) Electronic Prescribing for Controlled Substances (EPCS) Program on the CMS EPCS Prescriber Portal.

MY 2025 Compliance Status

As part of this compliance information, prescribers may review their initial MY 2025 compliance status, indicating their current status as compliant or non-compliant with the program for MY 2025, and any associated waiver application process or review available to non-compliant prescribers before CMS determines their final compliance status.

Note that prescribers, or their designated representatives, may submit a waiver application through the EPCS Prescriber Portal during the waiver application submission period of September 16–November 18, 2026.

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.

For more details on how CMS determines program compliance, visit the “Compliance Overview” section.

MY 2025 Non-Compliance Notification

The MY 2025 non-compliance notification period begins in September 2026. During this time, in addition to prescribers gaining access to their MY 2025 compliance information on the EPCS Prescriber Portal, CMS will issue prescribers identified out of compliance with the MY 2025 program requirement non-compliance notice. The non-compliance notice indicates that a prescriber has not met the EPCS program requirement for MY 2025 program and provides instructions for accessing their compliance status and how to submit a waiver application for MY 2025 on the EPCS Prescriber Portal.

When possible, CMS emails the non-compliance notice to non-compliant prescribers through CMSLists@subscriptions.cms.hhs.gov. However, if a prescriber doesn’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 will send the non-compliance notice as a physical letter. Physical letters will also be sent to those who do not open the non-compliance email notice and when emails are determined to be undeliverable.

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

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 the:

  • Getting Started Quick Reference Guide
  • EPCS Glossary
  • Requirements At-A-Glance
  • 2025 Declared Disaster Fact Sheet
  • 2026 EPCS Program Overview Slides
  • EPCS Frequently Asked Questions

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

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.

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

Graphic of CMS EPCS Program 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 through the 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

     

Important information about the CMS EPCS Program ⦁ Prescribers do not register for the CMS EPCS Program or send data directly to CMS. The CMS EPCS Program automatically calculates prescriber compliance using Medicare Part D claims. ⦁ Practitioners issuing electronic prescriptions for controlled substances must use a software application that meets all Drug Enforcement Administration (DEA) requirements. No additional e-prescribing software system is needed to meet the requirement for the CMS EPCS Program. ⦁ Prescribers experiencing technical issues when electronically prescribing controlled substances should contact their software vendor. Examples include log-in issues related to username or password, multi-factor authentication codes, or prescription transmission errors. ⦁ There is no requirement for Part D sponsors or pharmacists to verify that a prescriber has a waiver (or is otherwise exempt) from the CMS EPCS requirement before covering or dispensing a Part D drug. ⦁ The CMS EPCS requirement does not affect the ability of the Part D plan to cover or the pharmacists' ability to continue to dispense covered Part D drugs from otherwise valid written, oral, or fax prescriptions that are consistent with laws and regulations. ⦁ Prescribers of controlled substances can access the CMS EPCS Prescriber Portal to view their compliance rate and exception or waiver status in the fall following the measurement year. You must have a HCQIS Access Roles and Profile (HARP) account to access the portal.

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.
  • 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:

  1. 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.
  2. 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.

Archive

Educational Documents

2024

 2023

Webinar Recordings and Materials

Fall 2024 Webinar

Winter 2024 Webinar: CMS EPCS Program Updates and CY 2024 Medicare PFS Final Rule

Summer 2023 Webinar: CMS EPCS Program Update and CY 2024 Proposed Rule

Winter 2023 Webinar: CMS EPCS Program Rules for the 2023 Measurement Year

Downloads

Related Links

Page Last Modified:
09/16/2026 08:02 AM