Electronic Prescribing in ASC Settings: A 2026 Guide to ePrescribing, EPCS, Compliance, and Software

Electronic prescribing has moved well beyond being a convenience for ambulatory surgery centers. In 2026, it is an important component of medication safety, clinical workflow, regulatory compliance, and the overall transition from paper-based processes to connected ASC technology.

For surgery centers, however, implementing ePrescribing is not simply a matter of replacing a prescription pad with a computer screen. ASCs need to understand the difference between standard electronic prescribing and Electronic Prescribing for Controlled Substances (EPCS), evaluate federal and state requirements, enroll prescribers appropriately, build reliable workflows for post-operative medications, and select technology that works within the center’s broader clinical environment.

This updated guide explains electronic prescribing in ASC settings, including how the process works, the benefits, the federal requirements that apply in 2026, and what ASCs should consider when evaluating electronic prescribing software.

Compliance note: Electronic prescribing requirements can vary by state, prescription type, payer, prescriber, and clinical circumstance. ASCs should verify applicable requirements with their compliance advisors, legal counsel, state licensing authorities, and technology vendors.

What Is Electronic Prescribing?

Electronic prescribing, or ePrescribing, is the creation and electronic transmission of a prescription from an authorized prescriber to a pharmacy using an electronic prescribing system.

Instead of handwriting, printing, faxing, or physically giving a prescription to the patient, the prescriber enters prescription information electronically. It transmits it through a secure electronic network to the patient’s selected pharmacy.

Depending on the electronic prescribing software and its integration with the patient’s electronic health record, the process may also give clinicians access to:

• Patient demographics
• Current and historical medications
• Drug-allergy warnings
• Drug-drug interaction warnings
• Pharmacy information
• Insurance information
• Formulary or benefit information
• Prescription status and history
• Medication documentation within the patient’s chart

For an ASC, these capabilities can be particularly useful when prescriptions must be prepared accurately and efficiently around a tightly scheduled surgical encounter.

ePrescribing vs. EPCS

It is also important to distinguish ordinary ePrescribing from Electronic Prescribing for Controlled Substances, or EPCS.

EPCS involves electronically prescribing medications classified as Schedule II, III, IV, or V controlled substances. Because these medications present additional diversion and fraud risks, EPCS is governed by additional DEA security requirements.

DEA regulations require compliant electronic prescription applications for controlled substances and require practitioners to use two-factor authentication when signing controlled-substance prescriptions. Applications used for EPCS must also meet requirements under 21 CFR Part 1311.

In other words, an ASC should not assume that software capable of sending ordinary prescriptions is automatically configured or approved for EPCS.

How Does Electronic Prescribing Work in an ASC?

Although workflows differ by technology and facility, electronic prescribing in an ASC generally follows several steps.

1. The Patient and Pharmacy Are Identified

Patient demographics are selected or populated from the clinical record. The prescriber or clinical team confirms the patient’s preferred pharmacy.

Integration with an ASC’s electronic charting system can reduce duplicate demographic entry and help prevent transcription errors.

2. The Medication Is Selected

The medication, strength, dosage form, quantity, directions, and other required information are entered.

Depending on the software, the system may also display clinical warnings or other information relevant to the prescription.

3. The Prescription Is Reviewed

Clinical staff may assist with entering prescription information when permitted by workflow and applicable law, but the prescribing practitioner remains responsible for reviewing and authorizing the prescription.

For controlled substances, the DEA specifically requires the practitioner to review the prescription and affirmatively indicate that it is ready to be signed.

4. The Prescriber Signs the Prescription

For ordinary prescriptions, the authorization workflow depends on the system and applicable rules.

For EPCS, additional DEA requirements apply. The electronic prescription application must support compliant two-factor authentication, and the credential belongs to the individual practitioner authorized to prescribe the controlled substance.

5. The Prescription Is Transmitted Electronically

The prescription is sent through an electronic intermediary or prescribing network to the patient’s pharmacy.

DEA defines an intermediary as a technology system that receives and transmits an electronic prescription between a practitioner and a pharmacy.

6. Prescription Information Is Retained in the Clinical Workflow

With an integrated solution, medication information may flow back into the electronic chart, giving ASC staff a more complete record of what was prescribed during the surgical encounter.

This integration is particularly valuable in an ASC because the prescribing process should fit naturally into pre-operative, intra-operative, PACU, and discharge workflows rather than becoming a disconnected administrative task.

Benefits of Electronic Prescribing in ASC Environments

The benefits of electronic prescribing extend beyond eliminating handwriting.

Improved Prescription Legibility and Accuracy

Electronic prescribing eliminates errors caused by illegible handwriting and reduces manual transcription between the prescriber, patient, and pharmacy.

Structured medication fields can also help standardize information such as strength, dosage, quantity, and instructions.

Electronic prescribing does not eliminate medication errors, however. Safe workflows still require clinicians to verify the medication, dosage, patient, pharmacy, allergies, and clinical appropriateness before signing.

Greater Medication Safety Support

Integrated electronic prescribing software may support:

• Drug-drug interaction checking
• Drug-allergy checking
• Medication history review
• Duplicate therapy warnings
• Dose-related alerts

These features give clinicians additional information at the point of prescribing.

Better Security for Controlled Substances

EPCS adds controls intended to reduce opportunities for prescription alteration, theft, and unauthorized prescribing.

DEA requirements include identity-related controls, individual authorization, two-factor authentication, application requirements, audit capabilities, and electronic recordkeeping requirements.

This is considerably different from a paper prescription pad that can potentially be lost, stolen, copied, or altered.

Faster Pharmacy Communication

A properly transmitted electronic prescription arrives directly in the pharmacy’s electronic workflow rather than relying on a patient to deliver a paper document.

This can help reduce issues related to missing prescriptions, illegible handwriting, and manual data entry.

Electronic systems can also make pharmacy selection easier before the patient leaves the ASC.

More Complete Medication Documentation

When electronic prescribing is integrated with electronic charting, prescribed medications can become part of the patient’s clinical record without requiring staff to re-enter the information in multiple places.

This can improve continuity between the prescription itself and documentation of the surgical encounter.

Better ASC Workflow

For high-volume ASCs, even small administrative steps can become significant when repeated across hundreds or thousands of cases.

An integrated electronic workflow can reduce:

• Duplicate data entry
• Paper handling
• Prescription-pad management
• Calls related to unreadable prescriptions
• Time spent locating medication records
• Manual documentation of prescriptions in separate systems

CMS similarly identifies improved workflow, reduced data errors, improved patient safety, and reduced prescription fraud and irregularities as benefits associated with EPCS.

Electronic Prescribing Laws in 2026: What ASCs Need to Know

One of the biggest changes from earlier discussions of ePrescribing is that the federal controlled-substance requirement is no longer merely a proposed future rule.

The Federal EPCS Requirement

The SUPPORT for Patients and Communities Act was enacted in 2018. Section 2003 of the law generally requires Schedule II through V controlled substances covered under Medicare Part D or Medicare Advantage prescription drug plans to be prescribed electronically through a compliant electronic prescription program.

The CMS Electronic Prescribing for Controlled Substances Program implements this federal requirement.

Importantly, CMS evaluates prescribers, rather than treating the ASC itself as the unit of measurement. CMS uses the prescriber’s National Provider Identifier, or NPI, and qualifying Part D prescription claims to calculate compliance.

The 70% CMS EPCS Compliance Threshold

For the current CMS EPCS framework, a prescriber is considered compliant when at least 70% of qualifying Schedule II–V controlled-substance prescriptions for Medicare Part D beneficiaries are electronically prescribed, after applicable exceptions are taken into account.

That distinction is important for ASCs.

It means an ASC should not think about EPCS solely as a facility technology project. Individual physicians and other eligible prescribers practicing at the center need workflows that allow them to meet their prescribing obligations.

What Changed for 2026?

ASCs searching for a new law for electronic prescriptions in 2026 should understand that there is not one new federal law that suddenly replaces the existing framework.

Instead, the current environment combines:

1. The federal statutory EPCS requirement created by the SUPPORT Act.
2. CMS rules governing Medicare Part D EPCS compliance.
3. DEA regulations governing how controlled-substance electronic prescriptions must be created, signed, transmitted, and maintained.
4. State-specific electronic prescribing requirements.

CMS states that the CY 2026 Physician Fee Schedule final rule did not make changes to the CMS EPCS Program for measurement year 2026. As a result, the MY 2026 requirements remain the same as those for MY 2025.

This is an important update from the original 2021 discussion, when ASCs were still preparing for rules that had not yet reached their present implementation stage.

What About State Electronic Prescribing Laws?

Federal requirements are only one part of the compliance picture.

State electronic prescribing laws operate separately from the CMS EPCS Program. CMS explicitly notes that its EPCS requirements are distinct from state EPCS requirements.

Depending on the state, electronic prescribing requirements may apply to:

• Controlled substances
• Specific schedules of controlled substances
• Opioids or other categories of medications
• Non-controlled prescriptions as well
• Particular practitioners or practice situations

Exceptions also vary.

For an ASC with physicians who practice across multiple locations or states, the safest operational approach is to determine the applicable requirements for every jurisdiction in which prescriptions are issued rather than assuming compliance with the federal program satisfies state law.

CMS EPCS Exceptions and Waivers in 2026

The original approach of thinking of a waiver as “Option 1” for an ASC is no longer the most useful way to view the program.

CMS currently recognizes specific exceptions.

Small Prescriber Exception

CMS automatically provides a small prescriber exception to prescribers who issue 100 or fewer qualifying Medicare Part D controlled-substance prescriptions during the measurement year.

Declared Disaster Exception

CMS can automatically provide an exception to qualifying prescribers located in areas affected by certain declared emergencies or disasters. CMS identifies which declarations qualify for each measurement year.

CMS-Approved Waiver

A prescriber may also submit a waiver application when circumstances beyond the prescriber’s control prevented compliance.

The waiver process occurs through the CMS EPCS Prescriber Portal after the applicable measurement year according to the CMS compliance cycle.

A waiver therefore should not be treated as a substitute for implementing appropriate electronic prescribing technology where the prescriber is otherwise expected to comply.

What Happens When Electronic Prescribing Technology Fails?

ASCs also need a documented downtime process.

Electronic prescribing technology is highly dependent on:

• Internet connectivity
• ASC networks
• Prescribing applications
• Electronic intermediaries
• Pharmacy systems
• Authentication systems
• User credentials and devices

For controlled substances, a failed electronic transmission cannot simply be converted by the intermediary into a fax.

DEA guidance states that if an intermediary cannot complete transmission of a controlled-substance prescription, it must notify the practitioner. DEA provides specific alternative procedures in certain circumstances, including procedures for Schedule III–V prescriptions after a failed electronic transmission.

Because the rules differ based on controlled-substance schedule and applicable state requirements, ASC downtime policies should be developed with compliance guidance rather than relying on an improvised workaround.

Choosing Electronic Prescribing Software for an ASC

Not every electronic prescribing solution is equally appropriate for an ambulatory surgery center.

When evaluating electronic prescribing software, consider both regulatory capabilities and how the application fits into the ASC’s clinical workflow.

EPCS Capability and Compliance

If controlled substances will be prescribed, determine whether the application supports EPCS and meets applicable DEA requirements.

DEA requires applications used for controlled-substance ePrescribing to meet 21 CFR Part 1311 requirements. Applications must undergo an appropriate third-party audit or certification process before being used for EPCS.

ASCs should verify these capabilities directly with their vendor rather than assuming “ePrescribing” automatically includes EPCS.

Prescriber Identity Proofing and Authentication

Determine how prescribers are enrolled and what authentication process is required.

EPCS implementation commonly involves additional steps beyond creating an ordinary software username, because the system must establish appropriate credentials and access for each authorized practitioner.

Electronic Chart Integration

For an ASC, integration can be just as important as the prescribing feature itself.

Consider whether the solution can:

• Populate patient information from the chart
• Access medication history
• Check allergies and interactions
• Record medications prescribed during the ASC encounter
• Avoid duplicate documentation
• Maintain appropriate audit information

Mobile Access

ASC physicians frequently work across physician offices, hospitals, and surgery centers.

Evaluate whether prescriptions can be reviewed and authorized securely from the devices and locations physicians actually use while maintaining appropriate access and authentication controls.

Medication History

Access to recent medication information can give clinicians valuable context during the surgical encounter.

However, medication history obtained electronically should complement rather than replace the ASC’s medication reconciliation and patient verification processes.

Clinical Decision Support

Depending on the system, useful capabilities may include:

• Drug-allergy checking
• Drug-drug interaction checking
• Dose support
• Duplicate therapy alerts
• Formulary information

The objective should be meaningful clinical support without creating unnecessary interruptions or alert fatigue.

Audit Trails and Security

Medication systems handle protected health information and, in the case of EPCS, highly regulated prescribing activity.

Role-based permissions, authentication, audit trails, account management, and secure termination of access when clinicians leave the organization should be part of the evaluation.

Downtime and Failed-Transmission Workflows

Ask what happens when:

• A pharmacy cannot receive a prescription
• The prescribing network is unavailable
• Internet service is disrupted
• The prescriber loses an authentication device
• A prescription is sent to the wrong pharmacy
• The patient changes pharmacies after discharge

The exception workflow is part of the system’s usability, not an afterthought.

Standalone Electronic Prescribing Software vs. Integrated ASC Technology

An ASC generally has two technology paths.

Standalone ePrescribing

A standalone application may make sense when the ASC does not use electronic charting or when its existing technology does not provide the needed prescribing capabilities.

The tradeoff is that staff and providers may have another application to enroll in, learn, access, support, and maintain.

Information may also need to be entered in more than one system.

ePrescribing Integrated With the ASC’s Electronic Chart

When electronic prescribing is integrated with the ASC’s electronic chart, prescription activity can become part of the same workflow clinicians already use to document patient care.

That can minimize duplicate entry and make medication information easier to access across the surgical encounter.

For centers pursuing broader digital transformation, this can be a more scalable approach than adding multiple disconnected point solutions.

Electronic Prescribing With HST Pathways

For ASCs using or evaluating electronic charting, HST Pathways provides electronic prescribing functionality within HST eChart, its electronic charting solution designed specifically around ASC workflows.

HST eChart enables centers to send prescriptions from the electronic chart through ePrescribe powered by HST’s partnership with DoseSpot. Current functionality includes access to a patient’s 12-month prescription history, transmission of insurance information, and synchronization of medications prescribed in the ASC back into HST’s electronic charting environment.

HST eChart also provides immediate drug/drug and drug/allergy checking as part of its clinical capabilities.

The larger advantage of an integrated approach is workflow.

Instead of treating the prescription as a separate task performed in an unrelated application, clinicians can work from an ASC-specific electronic chart where patient information, clinical documentation, medication information, and prescription activity are more closely connected.

For ASCs that prescribe controlled substances, centers should work with HST Pathways and the applicable prescribing service to confirm current EPCS availability, prescriber enrollment requirements, configuration, controlled-substance workflows, and state-specific requirements for their organization.

A 2026 ePrescribing Implementation Checklist for ASCs

Whether an ASC is implementing electronic prescribing for the first time or reviewing an existing process, consider the following steps:

1. Identify every prescriber. Determine which physicians and other practitioners issue prescriptions associated with ASC cases.
2. Review federal requirements. Identify prescribers subject to CMS EPCS requirements and understand the current 70% compliance threshold.
3. Review applicable state laws. State electronic prescribing requirements may be broader than federal Medicare requirements.
4. Inventory existing technology. Determine whether your electronic chart or other ASC software already provides appropriate ePrescribing capabilities.
5. Confirm EPCS functionality. If controlled substances are prescribed, verify that the application and implementation support required DEA controls.
6. Complete prescriber enrollment. Allow sufficient time for credentialing, identity-related processes, access configuration, and authentication setup.
7. Define the clinical workflow. Determine when prescriptions will be prepared, reviewed, signed, transmitted, and documented.
8. Define responsibility. Establish who verifies the patient’s pharmacy, who can prepare prescription information, and who is authorized to sign.
9. Create downtime procedures. Build compliant processes for technology outages and failed transmissions before an outage occurs.
10. Train clinicians and staff. Include both the normal electronic workflow and exception procedures.
11. Review access regularly. Remove or update permissions promptly when physicians or staff change roles or leave the facility.
12. Monitor performance and compliance. Review prescribing activity, failed transactions, workflow problems, and regulatory updates routinely.

Electronic Prescribing Is Now Part of the ASC Technology Strategy

In 2026, the question for most surgery centers is no longer whether electronic prescribing will become important.

It already is.

The more useful questions are whether the ASC’s prescribing workflow is integrated, whether clinicians can use it efficiently, whether controlled-substance prescriptions meet the additional EPCS requirements that apply, and whether the organization is prepared for both federal and state compliance obligations.

The most effective electronic prescribing in ASC environments connects prescribing with the broader surgical workflow. Patient information, medication history, allergy and interaction information, prescription documentation, and clinical charting should work together wherever possible.

For surgery centers still relying on prescription pads, disconnected physician-office systems, or standalone workflows, evaluating an ASC-specific electronic chart with integrated prescribing capabilities can be an important next step toward reducing manual work and building a more connected clinical operation.

Ready to explore a more connected electronic prescribing and charting workflow? Learn how HST eChart helps ASCs bring clinical documentation, medication information, and ePrescription functionality together in an electronic environment designed specifically for surgery centers.