Q. May a practitioner use his/her own digital certificate to sign an electronic controlled substance prescription?
Actually, the following if I understand it correctly, seems doable. I am not sure where the certificate would reside, etc. Of course, there would need to be more changes to the software in order to use it.
A. Yes, the interim final rule allows any practitioner to use his/her own digital certificate to sign electronic prescriptions for controlled substances. If the practitioner and his/her application provider wish to do so, the two-factor authentication credential can be a digital certificate specific to the practitioner that the practitioner obtains from a certification authority that is cross-certified with the Federal Bridge Certification Authority at the basic assurance level.