Prescription Drug Monitoring Programs address the indisputable fact that society has recognized the overuse, misuse, abuse of prescribed controlled substances. As most drug overdoses were originally prescribed by a physician, attention has turned towards preventing the diversion of prescription drugs following dispensing. Both DEA and NYS Department of Health regulations mandate that, “the responsibility for the proper prescribing and dispensing of controlled substances shall be on the physician, dentist, podiatrist, veterinarian or other authorized practitioner, but a corresponding liability shall rest with the pharmacist who fills the prescription.” N.Y. Regs. 80.65
Prescription Drug Monitoring Programs (PDMPs) Operations
Prescription Drug Monitoring Programs (PDMPs) maintain statewide patient-specific electronic databases of prescriptions dispensed for controlled substances. PDMP organizational structures differ among the states, and PDMPs vary widely on whether and how information in databases is shared with practitioners in other states. The majority of states allow pharmacists and practitioners to access information for their patients across state lines.
New York Sharing of Prescription Monitoring Programs (PMP) Data
Since August, 2013, prescribers have been required, with limited exceptions, to check the New York PMP Registry prior to writing a prescription for Schedule II, III, and IV pharmaceuticals for a patient, and pharmacists have had access to the PMP Registry data since this date. New York practitioners may or may not have access to view other states’ registry data, depending on the access allowed in the other states. For example, some states may not allow pharmacist access. The submission of New York PMP data is the responsibility of the supervising pharmacist or owner, and the duty is non delegable. Submitting accurate data within 24 hours is necessary for effective use of the registry to identify patterns of prescribing, dispensing or potential abuse.
Accessing the PMP in New York
A Health Commerce System (HCS) account must be established to allow secure access to an individual’s controlled substance prescription history. Pharmacists may designate another pharmacist or pharmacy intern, but pharmacy technicians and other pharmacy employees are prohibited from access to the PMP Registry. Pharmacists are prohibited from providing a PMP report to any law enforcement official, including a DEA agent. Pharmacists may not access the PMP Registry without presentation of a prescription for dispensing.
National Council for Prescription Drug Programs (NCPDP) Position
Proponents such as the National Council for Prescription Drug Programs advocate creating a standardized nationally recognized data repository to establish a clinical risk score to assist with clinical prescribing decisions. This initiative is still under discussion, but is supported by many national pharmacy trade organizations.