Changes to Pennsylvania Drug Monitoring Program as of January 1, 2017: Compliance for Prescribing Physicians
January 16, 2017
Publications
Reprinted with permission from the January 2017 issue of Pennsylvania Psychiatric Society © 2017. Further duplication without permission is prohibited. All rights reserved.
By Julia Coelho
PaPS General Counsel
In August of 2016, under the authority of the Achieving Better Care by Monitoring All Prescriptions Program (ABC-MAP) Act (the “Act”), the Pennsylvania Department of Health (DOH) launched a prescription drug monitoring program (“PDMP”) including a statewide database (the “system”) for the collection of data on schedule II through schedule V controlled substances prescribed and dispensed to patients within the Commonwealth. Among other purposes, the PDMP seeks to alert medical professionals to instances of patient abuse of controlled substances, including prescription opioids. Physicians and pharmacists began registering with the PDMP on August 8, 2016 and the database became available for query on August 25, 2016. Although the program is still relatively new, its implementation to date has been successful with approximately 64,000 physicians and pharmacists signed up to use the database as of the end of 2016.
On November 2, 2016, Governor Wolf signed new legislation to further address opioid abuse and impose more stringent requirements on the prescription of opioid and benzodiazepine medications. The new legislation included certain amendments to Pennsylvania’s PDMP that became effective January 1, 2017. A summary of the updated PDMP’s registration, querying and medical record entry requirements for prescribing physicians is outlined below. Additional compliance information can be found at http://www.health.pa.gov/Your-Department-of-Health/Offices%20and%20Bureaus/PaPrescriptionDrugMonitoringProgram/Pages/GeneralInfo.aspx#prescribers
As “prescribers” under the Act[1], licensed Pennsylvania psychiatrists must ensure that they comply with PDMP requirements. Failure to comply with such requirements could result in disciplinary action against the prescriber’s license.
- Mandatory Registration for Pennsylvania’s PDMP. As of January 1, 2017, all licensed prescribers who are lawfully authorized to distribute, dispense, or administer a controlled substance in the Commonwealth must register with the program.
- Querying the PDMP System. A prescriber shall query the system: (i) 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 (“Initial Query”); (ii) if a prescriber believes or has reason to believe, using sound clinical judgment, that a patient may be abusing or diverting drugs; or (iii) beginning Jan. 1, 2017, each time a patient is prescribed an opioid drug product or benzodiazepine by the prescriber.[2]
- Medical Record Entries. A prescriber shall indicate the information obtained from the system in the patient’s medical record if: (i) the individual is a new patient; or (ii) the prescriber determines a drug should not be prescribed or furnished to a patient based upon the information from the system.
[1] This article addresses the requirements applicable to prescribers of controlled substances only. Prescribers who are also dispensers of controlled substances are subject to additional requirements as set forth in 35 P.S. § 872.7 (Requirements for dispensers and pharmacies).
[2] Effective January 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 as long as the patient remains admitted to the licensed health care facility or remains in observation status in such facility. Further, beginning on January 1, 2017, querying the system is not required for any medication provided to a patient in the course of treatment while undergoing care in an emergency department.
