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Chapter 32 - State Prescription Drug Monitoring Programs

Part 3 - Professional Services

Title Section
Introduction 3-32.1
    Purpose 3-32.1A
    Background 3-32.1B
    Definitions 3-32.1C
Responsibilities 3-32.2
    Area Director 3-32.2A
    Clinical Director 3-32.2B
    Pharmacy Director 3-32.2C
    Prescriber 3-32.2D
    Pharmacist 3-32.2E


  1. Purpose.

    The purpose of this chapter is to establish and define participation of the Indian Health Service (IHS) with State Prescription Drug Monitoring Programs (PDMPs).

  2. Background.

    The PDMPs are considered to be a tool for prescribers and pharmacists to monitor and deter prescription medication misuse, abuse, addiction and diversion and ensure appropriate clinical care.

    The PDMPs to date are State-based, electronic databases that collect data on controlled medications dispensed by registered pharmacies operating within the state.  These programs have a variety of purposes and goals, including:

    1. Supporting medication safety and legitimate medical access to controlled substances.
    2. Determining individuals who may be misusing, abusing or diverting drugs and preventing inappropriate access to controlled substances.
    3. Helping identify individuals addicted to controlled prescription medications and intervening with treatment.
    4. Influencing public health legislative and financial agendas by presenting prescription medication use data.
    5. Educating the public about the purpose of PDMPs and the issues surrounding prescription drugs.
    6. While the goals of State PDMPs are similar, vast variations exist within State legislation, PDMP logistics, and program administration.
  3. Definitions.
    1. Delegates.  Those healthcare professionals who have been recognized by State legislation with authorization to receive PDMP access or request patient queries.
    2. Dispensers.  The entities that must submit data to the PDMP for controlled drugs they have dispensed and administered.  This includes pharmacies (both in and out of State), hospitals, and any prescriber-based dispensing.
    3. Illicit Drugs.  Illicit drugs refer to marijuana, cocaine, inhalants, hallucinogens, heroin, or prescription-type drugs used non-medically.
    4. Prescribers.  Those clinicians who have the authority to prescribe controlled substances under State law.
    5. Memorandum of Understanding (MOU).  A formal agreement between the IHS Area and State PDMP that establishes the requirements for data disclosure to the State PDMP.  Examples of PDMP MOUs may be obtained by contacting the IHS Principal Pharmacy Consultant.
    6. Solicited Reporting (Also known as Reactive Reporting).  A request from the prescriber or delegate for patient profile information from the PDMP.
    7. Unsolicited Reporting (Also known as Proactive Reporting).  A report generated and provided by the PDMP to the prescriber or dispenser of a particular patient that has exceeded dispensing thresholds established by the PDMP.


  1. Area Director.  Ensures the PDMP MOU is current, signed, and archived as required in the terms of the MOU and as allowable by State law.
  2. Clinical Director.  All PDMP reporting and prescriber utilization shall be a function of the medical staff under the direct oversight of the Clinical Director.
  3. Pharmacy Director.  All Federal IHS pharmacy sites with an approved MOU between the IHS Area and the State in which the facility is located shall ensure that Schedule CII-CV dispensing data is reported at the frequency required by the State in which the facility is located.  Daily reporting is recommended to ensure a complete and accurate patient record.
  4. Prescriber.  The prescriber of a controlled substance prescription has the legal and ethical responsibility to ensure that all controlled substance prescriptions are issued in accordance with Federal law.  Valid prescribing is for a legitimate medical purpose that includes patient assessment, a documented treatment plan, and appropriate monitoring.  A PDMP query is one tool to assist practitioners with assessing patient prescription drug safe medication use, misuse, addiction, or diversion.  Prescribers must:
    1. Register with State PDMP.
    2. Request a solicited PDMP report as a normal process of accepting a new patient.  This information can assist the provider with determining any possible drug-drug interactions with any potential prescribed therapy or to identify recent doctor shopping behavior.
    3. Access PDMP patient data prior to patient appointment to facilitate meaningful interactions.  Providers should review PDMP data when opioid prescriptions for acute pain exceed 7 days, when progressing from acute to chronic opioid pain therapy, and periodically during opioid therapy for chronic pain, ranging from every prescription to every 3 months.  Data can help prescribers to:
      1. Check for drug interactions or other harm.
      2. Check for addiction or undertreated pain.
      3. Check for misuse or multiple prescribers.
      4. Use reports to verify compliance with safe medication use/pain agreements.
    4. Evaluate and respond appropriately to unsolicited PDMP reports.  Complete health chart review note regarding findings, prescriber assessment, and patient treatment plans.
    5. Use delegate accounts where authorized.  Delegates can help prescribers reduce time conducting queries.  Check with your state to see if delegates are allowed.  It is recommend a maximum of two delegate accounts per prescriber, as the prescriber is ultimately responsible for reports requested by the delegates.
    6. Perform self-audits monthly with a copy of the report provided to the Clinical Director.
  5. Pharmacist.
    1. The pharmacist shall access PDMP data during the following activities and discuss any potential abuse or diversion with prescribers:
      1. Prior to processing an outside prescription for a controlled substance.
      2. Every 3 months, prior to reissuing or refilling for a chronic controlled substance prescription for Schedules CII-CV medications.
    2. Pharmacists may:
      1. Assist with conducting PDMP queries upon prescriber request.
      2. Assist with provider education regarding report interpretation as appropriate.