[nyschp.dop] Re: Narcotic reporting
- From: "Jadoch, Christopher" <jodochc@xxxxxxx>
- To: "nyschp.dop@xxxxxxxxxxxxx" <nyschp.dop@xxxxxxxxxxxxx>
- Date: Thu, 5 Mar 2015 23:31:21 +0000
Sandra:
According to Public Health Law §3343-a, it deceivingly appears that only
pharmacies are required to report such transactions to the PMP (in pertinent
part - emphasis added):
Public Health
§ 3343-a. Prescription monitoring program registry. 1. Establishment
of system. (a) The commissioner shall, in accordance with the provisions
of this section, establish and maintain an electronic system for
collecting, monitoring and reporting information concerning the
prescribing and dispensing of controlled substances, to be known as the
prescription monitoring program registry. The registry shall include
information reported by pharmacies on a real time basis, as set forth in
subdivision four of section thirty-three hundred thirty-three of this
article.
HOWEVER, the NYS DOH regulation found in 10 NYCRR §80.71 does require that
dispensing practitioners report to the PMP electronically within 24 hours of
dispensing. I have been unable to find any exceptions for hospitals or
emergency departments regarding this requirement.
There are also references to this requirement for dispensing practitioners in a
number of the FAQs and newsletters issued by the NYS BNE on the topic of the
I-STOP and the PMP. See the bottom FAQ on page 6 of the FREQUENTLY ASKED
QUESTIONS for the NYS PMP issued by the BNE and revised in February 2014:
http://www.health.ny.gov/professionals/narcotic/prescription_monitoring/docs/pmp_registry_faq.pdf
Q: How is the controlled substance data in the PMP Registry obtained?
A: All New York State pharmacies and dispensing practitioners are required to
submit their controlled substance dispensing data to the Bureau of Narcotic
Enforcement.
Please let me know if anyone else offers additional or contrary insight to your
inquiry.
Regards,
Christopher Jadoch, R.Ph., J.D.
Vice President of Public Policy, NYSCHP
Assistant Professor
D'Youville College, School of Pharmacy
320 Porter Avenue
Buffalo, NY 14201
(716) 829-8340
Fax: (716) 829-8436
[DYC LOGO.JPG]
From: nyschp.dop-bounce@xxxxxxxxxxxxx<mailto:nyschp.dop-bounce@xxxxxxxxxxxxx>
[mailto:nyschp.dop-bounce@xxxxxxxxxxxxx] On Behalf Of Sandra Obleman
Sent: Thursday, March 05, 2015 4:54 PM
To: nyschp.dop@xxxxxxxxxxxxx<mailto:nyschp.dop@xxxxxxxxxxxxx>
Cc: Jerry R. Emmons
Subject: [nyschp.dop] FW: Narcotic reporting
Hello,
I would appreciate any insight any of you may have regarding the question below
from Jerry Emmons, MD, our ED medical director. I researched PMP FAQ issued by
NYDOH BNE but it only mentions a provider must consult the PMP registry if the
patient is going to leave with the controlled substance and consume it off the
institutional premises.
We are a rural community based hospital and the closest 24 hr retail pharmacy
is located about 45 min away. Our ED providers will dispense a small amount
of an ordered controlled substance in an appropriately labeled bottle to carry
the patient over until the local pharmacy opens in the morning.
Does anyone else in the list serve have this same practice? Does anyone have a
policy in place regarding this practice and how it pertains to ISTOP? Does
anyone in the group have ED providers that are reporting to the PMP registry if
they are dispensing controlled substances to a patient to take at home until
their pharmacy is open for business?
Thank you,
Sandra Obleman, PharmD
Director of Pharmacy
Oswego Hospital, Oswego, NY
T: 315-349-5719
From: Jerry R. Emmons [mailto:jermedic@xxxxxxxxx]
Sent: Thursday, March 05, 2015 8:38 AM
To: Sandra Obleman; Weitzel, Martin Kress D.O.; Boyle, Michael M.D.; Wajeeh
Sana MD; Frank Lackey; Kelly Montagna
Subject: Narcotic reporting
Hi Sandy,
I've copied the urgent care/ED directors on this email as well.
As I understand we are required to report to the PMP (ISTOP) program any time
we dispense a narcotic medication to go home with. How do we do this? Is there
an exemption for acute care facilities?
There has been discussion that the added layer of complexity/inconvenience will
cause us to not dispense these medications and simply administer a dose at the
time of discharge.
I appreciate your expertise on the matter!
--
Jerry R. Emmons, MD
Medical Director of Emergency Services
Oswego Hospital
Oswego, NY
Medical Director
Oswego County Ambulance Service
Greater Baldwinsville Ambulance Service
________________________________
This communication is from Oswego Health, Inc., or an affiliate, and is
intended solely for the use of the individual or entity to which it is
addressed. Information contained herein may include privileged and/or
confidential information. Unauthorized review, forwarding, printing, copying,
distributing or using such information is strictly prohibited and may be
unlawful. If you received this message in error or if you are otherwise
unauthorized to receive it, please promptly return to sender via email with a
copy to
privacyofficer@xxxxxxxxxxxxxxxx<mailto:privacyofficer@xxxxxxxxxxxxxxxx>, then
delete the original message and destroy all copies. Thank you.
Other related posts:
