As many of you know, PAs across Illinois are now required to register for the state’s Prescription Monitoring Program (PMP) and access the PMP for certain prescriptions. Here are a list of Frequently Asked Questions from the Illinois Department of Human Services for you to review and if you have further questions on these, you can contact the Department of Human Services at www.ilpmp.org or email our lobbyist Dan Shomon at firstname.lastname@example.org. The first three questions were posed by IAPA President Mindy Sanders and are more related to PAs and that’s why the answers are red.
Q: If prescribers have access to the PMP via their electronic health record, do they still need to register as individuals?
A: Yes, they will need to register separately on the website in order to be compliant with Public Act 100-0564.
Q: Also, it should be noted that when prescribers access the PMP via their electronic health record, the PMP is unable to track this. Our president Mindy Sanders brought this issue up on a PMP conference call. She accesses the PMP routinely through her EHR. She received an email from PMP stating that her username and password were going to expire because she had not used it recently.
A: The website and the automated connection are different, if a prescriber does not check the website for a year, the account will deactivate. The law says they must register not that they need to maintain active accts so I don’t think a deactivated acct makes them non-compliant.
- Is there a way to track this is in the notes of a patient in the EHR or are these notes protected by HIPAA?
- This is a question for the EHRs, I do believe some of them have this capability but it would need to be confirmed with the EHR system itself.
Q: Who must register on the PMP website?
A: All prescribers with a control substance license must register with the ILPMP regardless of practice.
Q: Does utilizing the PMP through the EHR automated connection mean that you are registered?
A: No, every prescriber must register on the PMP website to be compliant with Public Act 100-0564.
Q: What is considered “document the attempt to check the PMP”?
A: It will be up the prescribers and the health care organizations to develop internal policies to ensure compliance with the documentation portion set forth in Public Act 100-0564.
Q: What constitutes an “initial prescription”?
A: All CII scripts will be considered initial, since there are no refills on CII’s .
Q: Is there a penalty for failure to comply?
A: The Department of Financial and Professional Regulation (IDFPR) is generally authorized to take disciplinary or non-disciplinary enforcement action against any prescriber for failure to comply. Instances of non-compliance will be handled on a case-by-case basis. The IDFPR encourages early compliance, and will enforce new requirements to assist in the goal of reducing opioid abuse and overdose.
Q: Is there any way for a large provider (i.e. hospital) to check in “a batch way” to see if their employees have registered? They are encouraging compliance and want to make sure they are in compliance.
A: Each prescriber should register themselves on the website.
Q: Will there be any way for hospitals to get a list of those registered, so they can check on the backend to see who is not registered?
A: If a hospital can provide a list of users, we can verify those registered.
Q: If an inpatient is being ordered a new CS for in hospital use, does the prescriber (or their designees) have to look at the PMP first, before prescribing and dispensing? And if so, do both of them have to document somewhere in the EHR that they did?
A: We would consider inpatient use exempt from the requirements set forth in this public act.
(f) This Section shall not be construed to apply to inpatients, residents at hospitals or other institutions, or to institutional pharmacies.
Q: Is there an exemption for checking the PMP database for short-term prescriptions, i.e. 3 days or less?
A: The only exemptions listed include the following
- Oncology Treatment;
- Palliative Care;
- 7-Day or less supply provided by an Emergency Department (treating an acute, traumatic medical condition)
(f) This Section shall not be construed to apply to inpatients or residents at hospitals or other institutions or to institutional pharmacies.
Q: If the patient is receiving one dose of a pre-op Controlled Substance during an outpatient surgery, is accessing the PMP and documentation required?
A: It would not be required if the prescriber is not issuing an actual prescription, but it would still be considered best practice to know the patient’s controlled substance history.
Q: Where can I find information on designees?
A: The administrative rule can be found on our website or you can follow the link for more information http://www.ilga.gov/commission/jcar/admincode/077/077020800002100R.html
Q: Is there a limit to the number of designees a prescriber or dispenser may have?
A: Yes, they are limited to three.
Q: Can several prescribers designate the same designee?
Q: How does a prescriber or dispenser designate access to another individual? Do they have to go through your department, or can they just hand over their access codes?
A: We are in the process of creating a webpage that will allow for such access, both the prescriber and designee will need to register on the webpage and verify access. A user should never share their username and password.
Q: Do they have to identify whose agent/designee they would be? Do they need any specific information from the prescriber or dispenser?
A: The designee pages are in process and we hope to have them functioning soon. The designee and the prescribers will need to be linked with permission from both.