{
  "slug": "epcs-prescribing-signature",
  "title": "EPCS requires two factors. It does not require the prescriber.",
  "summary": "DEA rules make prescribers use two factors to sign controlled substance orders. The factors authenticate a session. Here is what binding them to the order changes.",
  "lede": "Electronic prescribing of controlled substances is one of the few places in American healthcare where a regulator demanded a signature on an individual act rather than a login. That was the right instinct. The problem is that the two factors authenticate a person into a session, and the session is what signs the order.",
  "date": "2026-09-26",
  "reading_time": "17 min read",
  "category": "Regulated",
  "tags": ["EPCS", "controlled substances", "21 CFR 1311", "electronic prescribing", "DEA", "clinical AI", "two-factor authentication"],
  "image": "https://cdn.twc.sh/images/igcache/EPCS%20Prescribing%20Signature/1200_630/blog.jpg",
  "url": "/blog/epcs-prescribing-signature.html",
  "wordcount": 3723,
  "related": ["approval-theater", "the-licence-is-not-the-person", "shared-account-attribution"],
  "schema": "Article"
}