Prescription Monitoring Program (PMP) goes into effect Nov. 1 – FAQs available

Posted on: 10/21/15

HB 1948, the Prescription Monitoring Program, goes into effect Nov. 1. The legislation clarifies language related to the Uniform Controlled Dangerous Substance Act and establishes a Prescription Monitoring Program for all prescribers: osteopathic and allopathic physicians, dentists, veterinarians, optometrists, nurses, and podiatrists. HB 1948 grants the sole responsibility for enforcement of the patient screening requirements to the licensing entity for each profession subject to the Act and a listing of the top 20 prescribers of controlled dangerous substances will be sent to their licensing entity.

Further, the measure:

  • Grants registrants access to the central repository for the purposes of patient treatment and for determination in prescribing or screening new patients and for refills if 180 days have elapsed prior to the previous access and check of opiates, synthetic opiates, semisynthetic opiates, benzodiazephine or carisoprodol;
  • Permits the patient’s history to be disclosed to the patient for the purposes of treatment of information at the discretion of the physician;
  • Establishes prescription limitations;
  • Provides for exceptions to the registry’s requirements;
  • Requires, upon discovering that a registrant is prescribing outside the limitations of their licensure or outside of drug registration rules or applicable state laws, the respective licensing board be notified by the Oklahoma State Bureau of Narcotics and Dangerous Drugs Control (OBNDD) in writing;
  • Clarifies that OBNDD has no authority to assess administrative fines and that respective licensure boards have exclusive authority to take action against licensees.

Inquiries from hospitals
OHA has received a number of inquiries on the impact of the PMP on hospitals. OHA staff has gathered several resources to share with members to help answer your questions. The Oklahoma State Medical Association has issued an FAQ, that is serving as guidance until the Oklahoma Board of Medical Licensure (OMBL) issues rules to implement the bill. This information is only being provided upon request by the OMBL and is not posted on a state website. In discussion with the staff at OBML, the licensure board(s) will not issue any FAQs due to their being considered legal authority that prescribers could rely on in the absence of official rulemaking.

Because the law goes into effect Nov. 1, the licensure boards for physicians, nurses and other prescribers will have to issue rules in the next several months for the implementation of the law. The delay in issuing rules has been coordination with the other licensure. These boards are important to oversight of hospital staff and the rules must be consistent.  

OHA staff has compiled a list of questions from OHA members, which are listed below, and sought guidance from various professional licensing boards. All professionals who write prescriptions must check the PMP starting Nov. 1. Check with your licensing board and go back to common sense as a licensed professional.

Question 1: Our emergency department physicians already frequently check PMP for patients when, in their judgment, the patient’s actions and statements are suspicious, or the patient is a “frequent flyer.” However, is this PMP check now a mandatory requirement for every patient regardless of circumstance?
Answer:The licensure is of the individual physician or nurse and, in this example, the ED physician should check the PMP for every ER patient. The intent of the law was for prescribers to check the PMP even for people who are known to the physician or don’t present as suspicious, as even non-suspicious persons can be overusing opioids. The Board of Medical Licensure as well as Osteopathic and Nursing Boards will be writing rules to hopefully address this question.

Question 2: At our hospital, hospitalists manage the care of most patients while in the hospital. The hospitalists regularly care for patients who are “new patients” to them. Upon discharge, patients return to their primary care physician for any follow up needed. Are hospitalists or other specialists (such as a radiologist prescribing a benzodiazepine prior to an MRI) exempt from running PMP reports on patients while in the hospital?  
Answer: There is no exemption for inpatients in a hospital from the law that alleviates the requirement that the physician check the PMP. To be safe, until rules are issued, the physician should check the PMP. The Board of Medical Licensure, as well as Osteopathic and Nursing, will be writing rules to hopefully address this question.

Question 3: When a patient is in the hospital and being cared for by their primary care physician (an OB/GYN delivering a baby, for instance), we will assume the provider has followed the HB 1948 requirements in their office practice. Do we have any responsibility to ensure this happens since the patient is in our hospital?
Answer: The law is not clear as to the responsibility of the treating physician within the hospital. Hopefully the primary OB/GYN has checked the PMP if a drug that is required to be checked is prescribed before the woman enters the hospital. Remember that the hospital is not licensed by these licensure boards, it is the individual that is licensed and subject to enforcement, so it is the responsibility of a physician that is writing a prescription for a drug on the PMP to check the registry. The Board of Medical Licensure, as well as Osteopathic and Nursing, will be writing rules to hopefully address this question.

If you have questions, please contact Sandra Harrison or Lynne White, (405) 427-9537. (Sandra Harrison)

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