Requirements for Prescribers
Act 191 of 2014 defines a prescriber as “a
person who is licensed, registered or
otherwise lawfully authorized to distribute,
dispense or administer a controlled
substance, other drug or device in the
course of professional practice or research
in the Commonwealth.” The term does not
apply to a veterinarian.
Pennsylvania’s Prescription
Drug Monitoring Program
What Dispensers
and Prescribers
Must Do to
Comply with
the Law
As of January 1, 2017, all prescribers with
an active license who are lawfully
authorized to distribute, dispense or
administer a controlled substance, were
required to have registered with the PDMP.
To register, log on to the Department of
Health’s website at
https://www.health.pa.gov/topics/
programs/PDMP/Pages/Register.aspx.
In 2014, the Pennsylvania
General Assembly passed
legislation to join 48 other states
in establishing a prescription
drug monitoring program.
The purpose of the program
is twofold: for practitioners to
use as a tool to increase the
quality of patient care and refer
patients to appropriate treatment;
and to aid regulatory and law
enforcement agencies in the
detection and prevention of
fraud, drug abuse and the
criminal diversion of
controlled substances.
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Act 191 of 2014 requires all practitioners
who dispense or prescribe controlled
substances to use the Pennsylvania
Prescription Drug Monitoring Program
(PDMP) in a number of ways. Failure to
comply with the mandates set forth in this
Act may result in civil or criminal penalties,
and in the Department of Health (which
operates the PDMP) reporting a licensee
to his or her licensing board for potential
disciplinary action. There are no penalties
for providers who do not dispense or prescribe
controlled substances; however, they are
encouraged to use the PDMP system as a
means to improve patient care.
Act 191 requires prescribers to query the
PDMP for an existing patient when the
following clinical situations apply:
• In circumstances in which a patient is
prescribed a controlled substance for the
first time 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, OR
• Each time a patient is prescribed an
opioid drug product or benzodiazepine
(this also applies to dosage changes
and refills).
As of January 1, 2017, dispensers are
required to collect and submit information
to the PDMP no later than close of
business the subsequent day. Prescribers
are required to query the system under
circumstances outlined below. The PDMP
stores the information in a secure database
and makes it available to health care
providers and other authorized users. *As part of good clinical practice, the
Department of Health recommends that
health care providers query the PDMP each
time a controlled substance is prescribed or
dispensed, even if it not a new controlled
substance.
To make consistent use of the PDMP more
practicable, prescribers and pharmacists
may grant access to any delegates under
their employment or supervision to query
the system on their behalf. • Acute or anticipated chronic controlled
substance prescriptions.
NOV E M B E R/DE CE M BER 2018 | P EN N S YLVA N IA D EN TA L J O UR NAL
These requirements apply to:
• Impatient and outpatient settings.
• New or established patients.
• Situations in which the prescriber is
covering for a colleague.