
The Arizona Controlled Substances Prescription Monitoring Program (“PMP”) was established in 2007 and provides the State of Arizona with a central database to track the dispensing of controlled substances. The PMP is designed to assist providers in making better-informed decisions and help “prevent the diversion and misuse of controlled substances at the provider, pharmacy, and patient levels.”[1]
PMP Requirements
Medical practitioners and pharmacists have similar responsibilities concerning the care of patients who are prescribed controlled substances. Since November 1, 2007, medical practitioners who are licensed to prescribe controlled substances must be registered with the PMP. As of October 16, 2017, prescribers are required to obtain a 12-month-lookback patient utilization report regarding a patient from the PMP before prescribing the patient a schedule II, III or IV “opioid analgesic or benzodiazepine controlled substance.” Prescribers must obtain this report at the beginning of each new course of treatment and at least quarterly while the prescription remains part of the patient’s treatment. Id.
In addition, for each schedule II, III, IV, and V controlled substance dispensed, prescribers and pharmacists must report certain information to the PMP, including: 1) the identity of and contact information for the prescriber, pharmacist, and patient; 2) the prescriber’s DEA registration number; 3) the name, strength, quantity dosage, and national drug code number of the controlled substance dispensed, the number of refills authorized, and whether the prescription is new or a refill; 4) the date the prescription was issued and dispensed; and 5) the patient’s method of payment.[2]
Effective January 26, 2018, the Arizona Opioid Epidemic Act (“Act”) established additional requirements and prohibitions for prescribing, administering, and dispensing schedule II opioids. Among other things, the Act prohibits medical professionals from dispensing opioids, with exceptions for physicians prescribing these substances for medication-assisted treatment; limits an initial prescription for an opioid to a 5-day supply, or a 14-day supply following a surgical procedure; prohibits a medical practitioner from issuing a new opioid prescription that exceeds 90 morphine milligram equivalents (MMEs), with exceptions; and requires the use of electronic prescriptions for opioids. The Act also requires pharmacists to register with the PMP and obtain a 12-month-lookback patient utilization report of a patient receiving a schedule II controlled substance at the beginning of each new course of treatment.[3]
Pharmacy Board Audits of PMP Data
The Arizona Board of Pharmacy (“Pharmacy Board”) plays a crucial role in overseeing the PMP. The Pharmacy Board operates, monitors, and maintains the PMP, and collects data on the prescribing and dispensing of controlled substances. The Pharmacy Board also provides education and training to healthcare providers, pharmacists, and the public concerning best practices in prescribing and dispensing controlled substances and raises awareness about the risks associated with their misuse.
Arizona law requires the Pharmacy Board to audit the data collected in the PMP and, if the Pharmacy Board believes that an “act of unprofessional or illegal conduct has occurred” or that a medical practitioner, pharmacist or pharmacy has failed to comply with PMP requirements, report such findings to the appropriate licensing board or law enforcement agency. The Pharmacy Board may disclose to such board or agency the information collected in the PMP.
It is not clear how often the Pharmacy Board must audit the PMP, or what data the Pharmacy Board must review. However, complaints recently filed by the Pharmacy Board with the Arizona Medical Board and Arizona Osteopathic Board reveal details about the Pharmacy Board’s audits. Each complaint included an audit report from the Pharmacy Board describing the physicians’ compliance with the PMP and prescribing statistics during a one-month period. The reports included the following data for the physician for that month: 1) the number of overlapping opioid and benzodiazepine prescriptions; 2) the number of opioid prescriptions for more than a 5-day supply to opioid naïve patients; 3) the number of prescriptions for 90 MMEs or more per day; 4) the total opioid prescriptions; and 5) the total benzodiazepine prescriptions written by the physician. The audits also described whether and how often the physician obtained patient utilization reports from the PMP during the month.
The rules and requirements for prescribing opiates, benzodiazepines and other controlled substances have grown increasingly comprehensive and complex. Medical practitioners who prescribe controlled substances and pharmacists who dispense controlled substances should ensure they are aware of their obligations regarding prescriptions for those medications.
If you would like more information about the PMP and its requirements, please contact Bob Milligan or Chelsea Gulinson.
[1] https://pharmacypmp.az.gov/arizona-pmp-team/about-arizona-pmp
[2] These reporting requirements do not apply to controlled substances administered directly to a patient; a controlled substance that is dispensed by a medical practitioner at a health care facility licensed by this state, within certain quantity limits; a controlled substance sample; the wholesale distribution of schedule II, III, IV, or V controlled substances; or a facility registered by the DEA as a narcotic treatment program.
[3] Prescribers and pharmacists do not have to obtain this report when prescribing these controlled substances to patients receiving hospice care, palliative care for a serious or chronic illness, cancer care, dialysis treatment, and in other limited circumstances.