[nyschp.dop] Re: Narcotic reporting
- From: "Michael Blumenfeld" <Michael.Blumenfeld@xxxxxxxxxxxxxxxxxxx>
- To: "nyschp.dop@xxxxxxxxxxxxx" <nyschp.dop@xxxxxxxxxxxxx>
- Date: Fri, 06 Mar 2015 08:12:32 -0500
We don't do any of this at Bellevue but in years past at another
location the practioner that dispensed a controlled substance provided a
copy of the Rx to the Pharmacy who entered the Rx and manually and
transmitted it within 24 hours. The providers were listed among the
Pharmacy verifiers. Not ideal because the dispenser isn't there to
confirm the info was entered properly by the Pharmacy the next day, but
it was all we could do. We limited the amount dispensed and I-Stop
would not be an issue because of limited number of days dispensed. Not
the ideal methodology, but we needed a way to ensure patients were
adequately serviced.
Michael Blumenfeld
Director of Pharmacy Services
Bellevue Hospital Center
P: 1-212-562-6504
C: 1-347-372-3877
F: 1-212-562-2936
Bellevue's Pharmacy charts the course to optimal pharmaceutical care
for the safety & welfare of our patients.
>>> "Jadoch, Christopher" <jodochc@xxxxxxx> 3/5/2015 6:31 PM >>>
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
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