Dear Pharmacists and Maryland PDMP Data Uploaders:
There are two groups of changes in the recently promulgated regulations for PDMP data collection: collection of naloxone dispenses and fields that are now required (vs. optional). The PDMP is also providing guidance on how to enter dispenses for animals from veterinarians.
During the Maryland 2022 Legislative Session, Chapter 224 “Public Health – Prescription Drug Monitoring Program (PDMP) – Naloxone Medication Data” passed. This means that dispensers who currently report controlled dangerous substance (CDS) dispenses to the PDMP will also begin reporting naloxone dispenses to the PDMP. The bill gave the start date of October 1, 2022; however, the regulations to guide this change were just promulgated.
As of March 2023, according to PDMP data, about 41% of dispensers were already reporting naloxone dispense to Maryland’s PDMP. For those not currently reporting, the Office of the PDMP has provided an implementation period to allow dispensers to operationalize the new naloxone reporting requirement until July 20, 2023.
As a reminder, these dispenses will not be viewable in the PDMP; the data will be used in aggregate for public health surveillance and planning.
We have updated the Maryland PDMP RxGov Data Submitter Reference Guide with changes dictated by the naloxone statute, changes to required fields, and new guidance from the American Society for Automation in Pharmacy (ASAP) for v4.2A & v4.2B.
In addition to the naloxone dispense change, the following ASAP fields that used to be optional are now required to be uploaded to the PDMP, starting on July 20, 2023, if they are not already being reported:
PAT02 ID Qualifier: this field is used together with PAT03 ID of Patient to describe the type of ID populated in PAT03. PAT20 Species Code: this field identifies if this prescription is for a human or a veterinary patient. DSP11 Drug Dosage Units Code: this field identifies the unit of measure for the quantity dispensed in DSP09. DSP17 Date Sold: this field indicates when the prescription was dispensed and left the pharmacy (vs. DSP05 Date Filled which is also a required field that indicates when the prescription was prepared). PRE01 National Provider Identifier (NPI): this field provides the NPI # for naloxone dispenses if the DEA # is not provided in PRE02. PRE06 First Name: this field provides the prescriber’s first name.
In an effort to better identify pet dispenses in the PDMP, Maryland is also supporting the national best practice by encouraging dispensers to enter the following fields:
PAT07 Last Name: If the prescription is written by a veterinarian, enter pet owner’s or handler’s last name. PAT08 First Name: If the prescription is written by a veterinarian, enter pet owner’s or handler’s first name. PAT18 Date of Birth: If the prescription is written by a veterinarian, enter pet owner or handler’s DOB. PAT20 Species Code (mentioned above) PAT23 Name of Animal (Optional)
Please forward any questions to firstname.lastname@example.org.
Maryland Office of the Prescription Drug Monitoring Program
Office of Provider Engagement and Regulation
Maryland Department of Health