The Florida Prescription Drug Monitoring Program, known as E-FORCSE® (Electronic-Florida Online Reporting of Controlled Substance Evaluation Program) was created by the 2009 Florida Legislature in an initiative to encourage safer prescribing of controlled substances and to reduce drug abuse and diversion within the state of Florida.
Below are three questions posed by a CFMGMA member and answered by Program Director Rebecca R. Poston, BPharm, MHL, for E-FORCSE Florida’s Prescription Drug Monitoring Program.
Physicians may not be directly reporting to the Registry/PDMP, but would be reporting to the pharmacy which shares data with the PDMP. Would that still meet the requirements from CMS? Would using the PDMP only “count” as fulfilling their obligations if you were dispensing, and therefore reporting, direct to the PDMP?
Yes, the eligible professional would be transmitting the electronic prescription to the pharmacy for dispensing and in turn, indirectly, the pharmacy is uploading the prescription information into the Registry/PDMP for the eligible professional’s review. We have confirmed that querying a patient to review their controlled substance dispensing history prior to prescribing would count as Active Engagement Option 3, Production and meets the MU Stage 2 objective.
Some dispensing physicians may be manually entering data into the PDMP rather than sending it through the CEHRT. Since the intent is for the EHR to share data directly with the registry, we want to clearly instruct our members. This way, they are aware of what the transmittal requirements are to meet the CMS Incentive Requirements when using PDMP. I don’t want our folks thinking they can manually enter and comply; which I actually have had that question.
It is my understanding the dispensing practitioner may use their certified EHR to create the file, however the file format for submission to the Registry/PDMP must be in accordance with the electronic reporting standards for the American Society for Automation in Pharmacy (ASAP) 4.2 format.
Once the dispensing data has been converted to the ASAP 4.2 format, the PDMP dispenser may meet the objective by electronically uploading their data by secure FTP over SSH; encrypted file with OpenPGP Via FPT; SSL website; physical media (tape, diskette, CD, DVD. Although the PDMP currently accepts universal claim form submissions manually, FAQ 13653 says manual entry into a web portal doesn’t count as submission, so I would think the using universal claim form submission upload method would not meet the objective.
What exactly does the Florida Statute 893.055(2)(a) and Administrative Rule 64K-1.002, American Society for Automation in Pharmacy Standards and Formats entail?
The format for submission to the database shall be in accordance with the electronic reporting standards of the American Society for Automation in Pharmacy (ASAP) contained in the “Implementation Guide ASAP Standard for Prescription Monitoring Programs Version 4, Release 2,” (9/2011), incorporated by reference. The PDMP will continue to accept reports in the ASAP 2009 version 4.1 standard for one year from the effective date of this rule (October 21, 2015), after which all reports must be made using the ASAP 2011 version 4.2 standard.
The format for submission to the database if no controlled substances are dispensed shall be in accordance with the incorporated by reference ASAP Zero Report Standard (9/2011). The agency has determined that posting the incorporated materials would be a violation of federal copyright law. The materials are available for public inspection at the Department of Health and the Department of State.
Department of Health
4052 Bald Cypress Way
Tallahassee, FL 32399
Department of State
R.A. Gray Building
500 South Bronough Street
Tallahassee, FL 32399.
A copy of the Electronic Reporting Standard for Prescription Monitoring Programs may be obtained from the American Society for Automation in Pharmacy.
American Society for Automation in Pharmacy
492 Norristown Road
Blue Bell, Pennsylvania 19422
Telephone (610) 825-7783
Rulemaking Authority 893.055 FS. Law Implemented 893.055 FS. History–New 2-20-12, Amended 10-21-15.
The Department of Health’s Prescription Drug Monitoring Program called E-FORCSE collects, maintains, and stores controlled substance prescription dispensing information in its database and makes the information available to health care practitioners and law enforcement and regulatory agencies during active investigations. Click here for more information.