Purpose and Legislative Background
Beginning January 1, 2013, the Massachusetts Department of Public Health Drug Control Program (DCP) is automatically enrolling physicians, dentists and podiatrists as participants in the Massachusetts Online Prescription Monitoring Program (MA Online PMP) upon obtaining a new Massachusetts Controlled Substance Registration (MCSR) or upon having their MCSR recalled.
In August 2012, major amendments pertaining to Chapter 244 of the Acts of 2012 were signed into law, designed to help prevent the diversion and abuse of prescription drugs. This guidance largely addresses the new requirement that physicians, dentists, and podiatrists who are obtaining a new or renewing their Massachusetts Controlled Substance Registration (MCSR) through recall be automatically enrolled in the Massachusetts Online Prescription Monitoring Program (MA Online PMP). Regulations will also go into effect on January 31, 2013 supporting additional requirements of the legislation. Guidance will be provided on the regulations when they are finalized.
An MCSR is required by Massachusetts General Laws Chapter 94C, section 7 in order to manufacture, distribute, prescribe, dispense, administer or possess a controlled substance.
For additional information about requirements to obtain an MCSR please review the "Frequently Asked Questions of Massachusetts Controlled Substances Registration (MCSR) Practitioner ".
The following address the most common questions concerning automatic enrollment of practitioners for the MA Online PMP.
1. What is the Massachusetts Online Prescription Monitoring Program?
The MA Online PMP is a website, hosted by the Virtual Gateway (the secure Web portal of the Executive Office of Health and Human Services), that provides a patient's prescription history for Schedule II – V prescriptions for the prior 12 months as reported by all MA pharmacies and by out-of-state pharmacies delivering to people in MA. The PMP prescription history data informs clinical decision-making to help prevent or stop harm from duplicate drug therapy, prescription drug, misuse or abuse and diversion.
2. What do I need to do to enroll in the MA Online PMP?
As of January 1, 2013, the Massachusetts Department of Public Health, Drug Control Program (DCP) is automatically enrolling physicians, dentists, and podiatrists as participants in the MA Online PMP upon obtaining a new MCSR or upon having their MCSR recalled.
- Recall forms now being sent to physicians, dentists, and podiatrists reflect changes that support the automatic enrollment process.
- Physicians, dentists, and podiatrists applying for a new MCSR must use the revised application form located on the DCP Website at: www.mass.gov/dph/dcp. Old versions of the blank application forms can no longer be processed and will be returned to the applicant. Please discard any old versions of the application forms.
- Both new and recalled MCSR applicants must complete the application form and sign under pains and penalties of perjury that the information submitted is correct and that they will abide by the Terms and Conditions for use of the MA Online PMP.
- After the MCSR certificate is issued, and as the application is processed, DCP initiates the process of obtaining login credentials for the registrant from the Virtual Gateway. Typically within 2-3 weeks of the certificate issuance, registrants are sent email messages with their password and with instructions for using the MA Online PMP.
3. What if my MCSR registration is not due to be recalled now?
Practitioner MCSRs are recalled every three years. Registrants who are not already MA Online PMP participants, and who are not due to be recalled soon, can download from the DCP website and submit an MA Online PMP Enrollment form. MCSR registrants may enroll at any time regardless of when their MCSR is due to be recalled. This does not affect the date that their MCSR will be recalled. There is no fee charged for enrolling in the MA Online PMP.
4. What do other prescribers and pharmacists need to know about enrollment in the MA Online PMP?
At the current time DCP is not implementing automatic MA Online PMP enrollment for advanced practice nurses, or physician assistants. These health care providers may voluntarily enroll by utilizing the appropriate enrollment forms on the DCP website.
Although pharmacist enrollment remains voluntary, the new legislation requires pharmacists to obtain continuing education on use of the MA Online PMP. More information concerning continuing education resources will be available after January 31, 2013.
5. Are Veterinarians automatically enrolled in the MA Online PMP?
No. Veterinarians are excluded from MA Online PMP enrollment. Veterinarians applying for a new MCSR need to download the separate MCSR application form for veterinarians which does not provide for MA Online PMP enrollment.
6. What do prescribers and dispensers need to know about requirements for using the MA Online PMP?
The new legislation has a requirement for health care providers enrolled in the MA Online PMP to utilize the system before seeing a new patient. DPH will be promulgating emergency regulations to go into effect on January 31, 2013 which will define the requirement and exceptions to the requirement. The regulations will be posted on the DCP website.
7. Do prescribers and dispensers still need to get the signatures on the MA Online PMP enrollment form notarized?
No. Signature notarization is no longer required.
8. What if I do not prescribe any Schedule II-V controlled substances?
Optometrists are excluded from prescribing Schedule II-V prescriptions, and are not being enrolled in the MA Online PMP. Physicians, dentists and podiatrists who elect to only have Schedule VI prescribing privileges will nevertheless be automatically enrolled in the MA Online PMP.
9. What happens if I do not want to be automatically enrolled in the MA Online PMP? Can I opt out of participating?
No. There are no provisions for practitioners in MA who want to opt out of the automatic enrollment in the MA PMP and prescribe controlled substances. DCP will refer those practitioners who do not agree to the terms and conditions of participating in the MA Online PMP to the applicable board.
Last updated: January 4, 2013
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