July 9, 2013


Summer is often a time we try to cut out early and ignore the heavy lifting.  Not so in 2013 - we have several practice changing requirements adjust to.  The first one coming - the Controlled Substance Registry is a new requirement effective August 27, 2013.  Now is the time to know what your requirements are and to start implementing procedure into your practice.  First step, sign up for your account -

Sign up for your health commerce account for your access to the registry click here - https://hcsteamwork1.health.state.ny.us/pub/top.html

Second step, get familiar with the system and your requirements.  I If you are entirely unfamiliar with the Registry - first you're hearing of this NYS requirement - the NYS Commissioner of Health is required to establish and to maintain an electronic system for collecting, monitoring and reporting information concerning the prescribing and dispensing of controlled substances.  This electronic system shall be known as the prescription monitoring program registry.  The registry shall include information reported by pharmacies on a real-time basis, included but not limited to:

      (i) the patient's name;
      (ii) the patient's residential address;
      (iii) the patient's date of birth;
      (iv) the patient's gender;
      (v) the date on which the prescription was issued;
      (vi) the date on which the controlled substance was dispensed;
      (vii) the metric quantity of the controlled substance dispensed;
      (viii) the number of days supply of the controlled substance dispensed;
      (ix) the name of the prescriber;
      (x) the prescriber's identification number, as assigned by the drug enforcement administration;
      (xi) the name or identifier of the drug that was dispensed; and
      (xii) the payment method.

A record of the patient’s controlled substances prescribed shall be available for no less than six months and no more than five years (the pharmacy retention requirement).  Pursuant to Section 3343-a of the Public Health Law, NYS government is required for maintaining the security of the registry and for implementing the registry, which is required to be secure, easily accessible, interoperable and compatible with the electronic transmission of prescriptions for controlled substances.  Protocols for the registry shall include the ability for the government to monitor and record access to the registry, which shall identify the authorized individual accessing and each controlled substance history accessed.

Practitioner’s Duty to Consult
As of August 27, 2013 practitioners are required to consult the prescription monitoring program registry prior to prescribing.  As of that date, every practitioner (except the list below) shall be required to consult the registry prior to prescribing or dispensing any schedule II, III or IV controlled substance.  NYS Public Health law does provide that practitioners may delegate the “consulting” responsibility to an authorized and competent designee employed by the practice. At all times the registered practitioner shall be remain responsible for ensuring that access to the registry is proper, and shall remain responsible for any breach.  Also, the ultimate decision as to whether or not to prescribe or dispense a controlled substance shall at all times remain with the practitioner.   If any designee of the practice is terminated or leaves the practice’s employ for any reason, the practitioner shall have the responsibility of notifying the Department of Health and adequately protecting registry access. 
For more information, view the I-STOP webinar located here.

Reference: NY CLS Pub Health § 3343-a