Prescription Monitoring Program for veterinarians – Need a refresher?
Washington State Department of Health’s Prescription Monitoring Program (PMP) is established under Chapter 70.225 RCW. The PMP is a repository that collects, and makes available to healthcare professionals (HCP), data reported by dispensers. It is essential that data reported to the PMP be accurate, complete and timely submitted.
HCPs are encouraged to make reports of missing and inaccurate PMP data so PMP staff members can follow up with dispensers to ensure PMP data quality. It’s critical dispensers work quickly to correct data errors. Erroneous data can lead to patient harm. Non-compliance with PMP data reporting requirements will be reported to the dispenser’s licensing authority.
Veterinary dispensers report controlled substance dispensing data to the PMP under RCW 70.225.020 (c) (i – iii) and WAC 246-470-035 for their animal patients. The Veterinarian Dispensers’ Implementation Guide for Veterans (PDF) is available from the PMP homepage with information and instructions for reporting. Reports can be automated from a dispenser’s record system, or can be input to the PMP system via web portal. A provision also allows dispensing veterinarians to fax information to the department for input by program staff members.
Data Collection Requirements
- Name of animal for whom drug was dispensed plus owner’s last name
- Animal’s date of birth (or if date of birth is unknown, enter January 1st of the estimated birth year)
- Animal’s species
- Owner’s name and address
- Prescription number, date written plus date filled
- Drug dispensed plus quantity and day’s supply
- Prescriber’s DEA number, first and last name
- Dispenser’s DEA number, first and last name
- Valid ID of animal’s owner
Animal owner information is reported and recorded as the “person dropping off or picking up the prescription” (ASAP fields AIR 4, 5, 6, 7, 8, 11 – page A-46 of the implementation guide). Dispensing veterinarians are required to report all controlled substance medication dispenses of more than 14 day’s supply within 10 days of the close of the calendar quarter (report due dates: April 10; July 10; October 10; January 10). Nothing in statute or rule prohibits a veterinary dispenser from more frequent or more thorough reporting to PMP.
Veterinary controlled substance prescriptions filled by a pharmacy are reported in accordance with pharmacy dispenser requirements. Nothing in statute or rule prohibits more frequent or more thorough veterinary dispenser reporting to PMP.
PMP statute (RCW 70.225.040 (3)(a)) authorizes healthcare providers patient query access for providing medical or pharmaceutical care to their patients, meaning veterinarians can query the system for their animal patients’ prescription history, but not for their owners’ prescription history. The PMP often has limited utility for a prescribing veterinarian working to understand or confirm drug-seeking behavior of an animal owner. Despite these limitations, veterinary dispenser data is an important component to understanding the ongoing opioid epidemic in our state.
Reporting Zero Dispensing
If you have no dispenses to report for the preceding reporting period, you must report this information to the Washington State Department of Health.
PMP FAQ for Veterinary Dispensers
May a dispensing veterinarian stop reporting if he or she decides not to dispense anymore?
Requirements for reporting are based on dispensing of controlled substance medication. If a veterinarian (or other healthcare provider) is not dispensing these mediations, there is no requirement to report. Program compliance is geared to look for activity related to dispenser DEA registration numbers. Should a veterinarian decide to no longer dispense controlled substance medications, they should consider either terminating their DEA registration (where appropriate), or submitting a “No Dispensing of Controlled Substance” waiver to attest they no longer dispense these medications.
What are the consequences for not reporting?
Enforcement and consequences for failure to meet reporting requirements as outlined in statute and rule are determined by the dispenser’s disciplinary (licensing) authority under Washington’s Uniform Disciplinary Act (UDA); for veterinarians this will be the Veterinary Board of Governors. Under the UDA, violation of state or federal law may lead to disciplinary action, license censure, and license revocation (UDA FAQ). The Prescription Monitoring Program is a healthcare provider information tool focused on patient safety, not an enforcement tool. Program staff members monitor and report compliance but have no role in enforcement.
Can the PMP be used to look up a suspected drug seeker?
PMP statute (RCW 70.225.040 (3)(a)) limits healthcare provider patient query access to providing medical or pharmaceutical care for their patients, meaning veterinarians can query the system for their animal patients’ prescription history but not for their owners’ prescription history. The PMP often has limited utility for a prescribing veterinarian working to understand or confirm drug seeking behavior of an animal owner. Despite these limitations, veterinary dispenser data is an important component to understanding the state of the ongoing opioid epidemic in our state.
I don’t have a records system capable of automated reporting to PMP. What’s the best way for me to submit my required dispensing reports?
Where automation is not available for veterinary dispenser reporting, it’s often quicker and easier to submit data directly through the PMP web portal. Submitting data via fax is allowable but can add time and work especially where corrections, and clarifications are needed from the dispenser. More information and assistance with reporting is available from the PMP Technical HelpDesk at the Washington State Department of Health. Please contact us at [email protected] or (360) 236-4806 (option #2).
What if we get behind in our reporting?
Although every endeavor should be made to report by the deadline, late reports are accepted.
What if all we have is our client’s P.O. box?
P.O. boxes are accepted, but physical addresses are preferred. This allows the PMP to more accurately map the data.
Do I have to report to the PMP when I administer controlled substances in the hospital?
No, veterinarians only report controlled substances that are dispensed to the client.
Do I have to report to the PMP any prescriptions for controlled substances that I write?
No, pharmacies report to the PMP controlled substance prescriptions they fill on your behalf.
Can veterinarians designate a representative to submit reports to the PMP?
Yes, it’s common for veterinarians to delegate the reporting to a staff member.
General tips for PMP dispenser-reporters
These are not specific to veterinary data and may not apply to veterinary data reporting in some cases:
PMP Data Compliance – Items of Concern
The PMP data issues below are systemic, with (specific) errant data having been reported by numerous pharmacies. They may point to dispensing software issues when the errant data comes from multiple (or all) pharmacies of the same chain. Please review the issues below and work to ensure data reported from your pharmacy’s system is reported correctly.
Refills vs Partial-Fills
Federal and state law prohibit refills for CII substances. Refills for CII substances have been reported by pharmacies in contrast with these federal and state laws. The timeframe for the observed increased CII refill reporting correlates with CARA legislation allowing for controlled substance partial fill (July 22, 2016 forward). Pharmacy systems may need to be upgraded to allow proper recording of partial fill information.
Unverifiable DEA Registration Numbers
Federal and state laws prohibit dispensing controlled substances without valid DEA registrations for the prescriber and the dispenser. PMP requires DEA registrations for the prescriber and the dispenser be reported for each record. The PMP system automatically checks each reported DEA registration number.
- Review your internal policies on what to do if the DEA registration number on a controlled substance prescription is illegible.
- Work to ensure unverifiable DEA registration numbers are not submitted to the PMP.
- Work to correct any reported unverifiable DEA numbers following the steps for a record revision in the Veterinarian Dispensers’ Implementation Guide for Veterans (PDF)
By Gary Garrety, WA State Department of Health. He can be reached at [email protected]
Posted May 10, 2019