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What Pennsylvania Physicians Need to Know about the Prescription Drug Monitoring Program

Pennsylvania physicians who are licensed, registered, or otherwise lawfully authorized to prescribe controlled substances, other drugs or devices in the course of professional practice or research in this Commonwealth are required to register in the state's new prescription drug monitoring program (PDMP). The Department of Health's (DOH) PDMP webpage contains more information, including a link to register.

According to the law, once registered, prescribers shall query the system for each patient the first time the patient is prescribed a controlled substance by the prescriber for purposes of establishing a baseline and a thorough medical record.

A prescriber shall also query the system if he or she believes or has reason to believe, using sound clinical judgment, that a patient may be abusing or diverting drugs.

Beginning Jan. 1, 2017, prescribers will also be required to query the system each time a patient is prescribed an opioid drug product or benzodiazepine by the prescriber.

A Fall 2016 amendment to the PDMP law now requires DOH to ensure that prescribers are registered with the PDMP system. Specifically, starting Jan. 1, 2017, DOH will be required to “develop policies and procedures to require and ensure registration of all prescribers and dispensers with the program."

If you have not already done so, please register as soon possible so that you are prepared to query the system. A tutorial to walk you through the registration process can be found here.

See a list of frequently asked questions by PAMED members.

See information on four new laws that updated requirements to the PDMP in November 2016.

Below is additional information on the state's new PDMP program, provided by DOH:

Querying the PDMP System – Requirements for Prescribers

A prescriber shall query the system:

  • For each patient the first time the patient is prescribed a controlled substance by the prescriber for purposes of establishing a baseline and a thorough medical record; or
  • If a prescriber believes or has reason to believe, using sound clinical judgment, that a patient may be abusing or diverting drugs.
  • Beginning Jan. 1, 2017, each time a patient is prescribed an opioid drug product or benzodiazepine by the prescriber.

Querying the PDMP System - Additional Access for Prescribers

A prescriber may query the system for:

  • An existing patient; and
  • Prescriptions written using the prescriber's own Drug Enforcement Administration number.

Assigning Designees - Prescribers

Prescribers may designate employees as designees for purposes of accessing the system according to standards established by the ABC-MAP Board. In assigning a designee, a prescriber shall give preference to a professional nurse licensed by the State Board of Nursing.

Exceptions to the Querying Requirement – Prescribers

Beginning Jan. 1, 2017, if a patient has been admitted to a licensed health care facility or is in observation status in a licensed health care facility, the prescriber does not need to query the system after the initial query required under the law as long as the patient remains admitted to the licensed health care facility or remains in observation status in a licensed health care facility.

Beginning Jan. 1, 2017, health care practitioners who are providing medication to a patient in the course of treatment while the patient is undergoing care in an emergency department are not required to query the system.

Submitting Information to the PDMP System - Requirements for Dispensers

Pharmacies (including mail order and Internet pharmacies), in addition to health care practitioners who dispense scheduled II – V controlled substances that are not exempt as detailed below, will be required to electronically report prescription dispensing information to the PDMP.

Beginning Jan. 1, 2017, when a controlled substance is dispensed, the information must be reported to the system no later than the close of the subsequent business day after dispensing a controlled substance. Previous to this, dispensers had up to 72 hours to report into the system. This dispenser reporting requirement went into effect on June 24, 2016.

Beginning Jan. 1, 2017, dispensers will be required to query the system before dispensing an opioid or a benzodiazepine prescribed to a patient if any of the following apply:

  • The patient is a new patient of the dispenser. A new patient does not include an individual going to the same pharmacy, or a different physical location of that pharmacy, if the patient's record is available to the dispenser.
  • The patient pays cash when they have insurance.
  • The patient requests a refill early.
  • The patient is getting opioid drug products or benzodiazepines from more than one prescriber.

Exemptions — A health care practitioner is not considered a dispenser, and thus will not be required to report to the PDMP system, when he/she/it is a/an:

  • Licensed health care facility that distributes the controlled substance for the purpose of administration in the licensed health care facility.
  • Correctional facility or its contractors if the confined person cannot lawfully visit a prescriber outside the correctional facility without being escorted by a corrections officer.
  • Authorized person who administers a controlled substance, other drug, or device.
  • Wholesale distributor of a controlled substance.
  • Licensed provider in the Living Independence for the Elderly (LIFE) program (LIFE is a managed care program that provides medical and supportive service to eligible older individuals so they can continue to live independently).
  • Provider of hospice as defined in the act of July 19, 1979 (P.L.130, No.48), known as the Health Care Facilities Act.
  • Prescriber at a licensed health care facility if the quantity of controlled substances dispensed is limited to an amount adequate to treat the patient for a maximum of five days and does not allow for a refill.
  • Veterinarian.

Even if practitioners fall under one of the dispensing exemptions listed above, the exemption does not relieve them from having to query the PDMP system as explained above.

Information to be Submitted by Dispensers

A dispenser or pharmacy shall electronically submit information to the system regarding each controlled substance dispensed:

  • The full name of the prescriber.
  • The prescriber's Drug Enforcement Administration (DEA) registration number.
  • The date the prescription was written.
  • The date the prescription was dispensed.
  • The full name, date of birth, gender and address of the person for whom the prescription was written and dispensed.
  • The National Drug Code (NDC).
  • Quantity and Days' supply.
  • The DEA registration number and National Provider Identifier of the dispenser or pharmacy.
  • The method of payment for the prescription.

Assigning Designees - Dispensers

Dispensers may designate other pharmacy employees for the purpose of accessing the system based on standards established by the ABC-MAP Board.

Querying the PDMP System - Dispensers

A dispenser or pharmacy may query the system for a current patient to whom the dispenser is dispensing or considering dispensing any controlled substance.

Confidentiality of PDMP System Information

The information being collected is safeguarded in both its collection and distribution. By state law, the data is confidential and not subject to disclosure under the act of Feb. 14, 2008 (P.L.6, No.3), known as the Right-to-Know Law. Access is restricted to approved, authorized users identified in the act of Oct. 27, 2014 (P.L. 2911, No. 191, known as the Achieving Better Care by Monitoring All Prescriptions Act).

Why Registering for System Access Will Be Important to Your Daily Practice of Medicine

  • When access is granted, you can log on and view controlled substance prescription history of your patient. If you see a pattern of excessive use of controlled substances, you can use more caution in prescribing or dispensing to the patient.
  • The database allows prescribers to detect pharmacy errors or fraudulent use of their DEA numbers. With access to the PA PDMP, a prescriber can query to find out which prescriptions for controlled substances were attributed to their DEA number.
  • When preparing for new patients, big or small practice physicians with access can query or allow their delegates to query for prescription information on a new patient they will be seeing at a future appointment. This allows you to check on a patients' Schedule II - V controlled substance drug history and look for any red flags before prescribing a controlled substance to the new patient.
  • The PDMP provides an important tool to health care professionals. It is intended to serve as a means to promote and improve patient well-being through better coordination of care, and to reduce the risk of addiction, diversion and overdose. It is not intended to interfere with the legitimate medical use of controlled substances.

Prescriber Resources and Education

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mfraser

Tuesday, May 10, 2016 7:17:43 PM

mfraser

Great overview

Tuesday, May 10, 2016 7:18:17 PM

wmurdoch

A few quick questions come to mind. How will the State know if we have checked the PDMP site each and every time we refill and Rx? What if we give a few months medications with the originating date but instructions do not fill before date? Do we only check on the originating date, or with each monthly Rx that will later be filled? and how will we know the exact date the refill is requested? Will we have a few days to check the PDMP, especially if we are doing a refill by phone in for a Benzo while out of the office? What does the state consider a Benzodiazepine- does this include hypnotics like Lunesta, Ambien, Sonata, Temazepam, etc.? What is the penalty for forgetting one time out of hundreds a year, for checking the PDMP site? Will the dispensing pharmacy not be able to dispense an Rx that we wrote if they do not have documentation that the PDMP was cleared by us first? Did any real full time practicing doctors participate in this new rule change, and if so, can we do a PDMP check on them?

Thursday, November 10, 2016 4:26:47 PM

nrahmanian

Who is going to pay for all the extra work. Checking every time as opposed to once a year or with the first prescription is bordering on harrassment or at least a large hassel factor since it has to be done monthly. This is one time PMS has failed us. Very disappointed.

Thursday, November 10, 2016 8:16:05 PM

msiget

wmurdoch, Thank you for your questions. I will try to answer as many as I can. 1. How will the state know? The Department of Health has the authority to audit the PDMP system. 2. When to check? You are required to check prior to issuing the prescription. 3. How much time do you have to check? You are required to check prior to issuing the prescription, regardless of whether it is by phone or in person. 4. What is a benzodiazepine? Act 124 has a definition here: http://www.legis.state.pa.us/CFDOCS/Legis/PN/Public/btCheck.cfm?txtType=PDF&sessYr=2015&sessInd=0&billBody=S&billTyp=B&billNbr=1202&pn=2199 5. Penalties: As with the original PDMP law, the state boards have the authority to take disciplinary action against a license. Ultimately, those decisions will be made by the state boards. 6. Dispensers: Dispensers are not required to verify that a prescriber has checked the PDMP system. Dispensers do have their own requirements for checking the system. 7. PDMP checks: There are limited people who are allowed to check whether a prescriber has accessed the system. Physicians are not permitted to check up on other physicians.

Monday, November 14, 2016 9:14:20 AM

msiget

To add to my comments, the Department of State may also access the PDMP system for investigatory purposes.

Monday, November 14, 2016 11:06:34 AM

wmurdoch

To msiget 1. How will the state know? The Department of Health has the authority to audit the PDMP system. OK makes sense 2. When to check? You are required to check prior to issuing the prescription. Great not very easy to do on the go via cell phone- I did check and it looks like I can make an attempt from my I phone, but again how cumbersome for every Rx!! 3. How much time do you have to check? You are required to check prior to issuing the prescription, regardless of whether it is by phone or in person. 4. What is a benzodiazepine? Act 124 has a definition here: http://www.legis.state.pa.us/CFDOCS/Legis/PN/Public/btCheck.cfm?txtType=PDF&sessYr=2015&sessInd=0&billBody=S&billTyp=B&billNbr=1202&pn=219 I looked this up and here is what the law states as per the useless link to the Law- "BENZODIAZEPINE." A PSYCHOACTIVE DRUG WHOSE CORE STRUCTURE IS THE FUSION OF A BENZENE RING AND A DIAZEPINE RING, AND WORKS ON THE CENTRAL NERVOUS SYSTEM PRIMARILY ON THE GABA (A) RECEPTORS IN THE BRAIN Are you kidding me?? again see my prior post- how about sleep meds like restoril = temazepam, ambien = zolpidem, sonata = Zaleplon, lunesta = eszopiclone????? 9 5. Penalties: As with the original PDMP law, the state boards have the authority to take disciplinary action against a license. Ultimately, those decisions will be made by the state boards. Great, a State Board that has the power to take unlimited action against a provider without any requirement of due process. What could possibly go wrong here?? 6. Dispensers: Dispensers are not required to verify that a prescriber has checked the PDMP system. Dispensers do have their own requirements for checking the system. OK, at least my patients won't be furious if I tell them I am calling in an Rx, but am driving and cannot access the PDMP immediately prior to calling it in. The Rx will still get filled though I may lose my license in the process. 7. PDMP checks: There are limited people who are allowed to check whether a prescriber has accessed the system. Physicians are not permitted to check up on other physicians. This was a response to my comment; Did any real full time practicing doctors participate in this new rule change, and if so, can we do a PDMP check on them? Um, that was humor, not a real request, but now, maybe not??

Monday, November 14, 2016 4:55:09 PM

1549-child-abuse

I have staff that checks this for me, so it is going just fine. If I was doing this solo, wow! Very cumbersome. What about those electronically prescribed Rx's with Do Not Fill Before dates-usually Rx for 1 month for now then q 30 days for 2 additional Rx's to carry patient for 3 mos? Am I required to store those dates and check PDMP each month? By definition I am doing this type of prescribing for patients who have gained my trust. If I just check system when I write original Rx am I breaking the law? Must I tell patients I can no longer accomodate them? Maybe this has not been thought entirely through but we can work these bugs out, we simply must know where we might inadvertently get into trouble.

Friday, February 3, 2017 10:16:51 PM

jeffwirick

Thank you for your question. The Department of Health answered this question on its PDMP website. You can access the prescriber FAQ page at http://www.health.pa.gov/Your-Department-of-Health/Offices%20and%20Bureaus/PaPrescriptionDrugMonitoringProgram/Pages/GeneralInfo.aspx#prescribers. Q: If I issue three 30-day controlled substance prescriptions to cover a 90-day supply, do I need to query the PDMP system three times? A: No, you would only need to query the PDMP system once, at the time you issue the prescriptions to the patient.

Monday, February 6, 2017 11:33:39 AM

msiget

Thank you for your question. The Department of Health answered this question on its PDMP website. You can access the prescriber FAQ page at http://www.health.pa.gov/Your-Department-of-Health/Offices%20and%20Bureaus/PaPrescriptionDrugMonitoringProgram/Pages/GeneralInfo.aspx#prescribers. Q: If I issue three 30-day controlled substance prescriptions to cover a 90-day supply, do I need to query the PDMP system three times? A: No, you would only need to query the PDMP system once, at the time you issue the prescriptions to the patient.

Monday, February 6, 2017 11:33:54 AM

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