Physicians and other prescribers are reminded that on Saturday, April 1, Act 266 will require a practitioner to review a patient’s records under the Prescription Drug Monitoring Program (PDMP) before issuing a prescription order for a monitored drug. Under the statute, there are exceptions to the mandate:
- The patient is receiving hospice care, as defined in s. 50.94 (1) (a).
- The prescription order is for a number of doses that is intended to last the patient three days or less and is not subject to refill.
- The monitored prescription drug is lawfully administered to the patient. For example, a drug that is both prescribed and administered to a patient on an inpatient unit is exempted.
- Due to emergency, it is not possible for the practitioner to review the patient’s records under the program before the practitioner issues a prescription order for the patient.
- The practitioner is unable to review the patient’s records under the program because the digital platform for the program is not operational or due to other technological failure if the practitioner reports that failure to the Board.
On March 30, the Department of Safety and Professional Services (DSPS) sent an email providing a procedure for implementing the exception for inability to review PDMP records due to PDMP technological or operational failure. It states:
"As you may be aware, Wis. Stat. ch. § 961.385(2)(cs)2.e. offers an exception to the ePDMP requirement should the ePDMP not be operational or if there is a technological failure if the practitioner reports that failure to the board. Under this section, "board" is defined as the Controlled Substances Board (Wis. Stat. ch. §961.385(1)(ac), and notifications should be provided following the below procedure:
To report a technological failure preventing you from accessing the WI ePDMP, send an email to PDMP@wisconsin.gov with the subject line "WI ePDMP Tech Failure."
WHA has been receiving reports and notices of both planned and unplanned outages of the ePDMP in the days leading up to April 1. If your organization’s prescribers are having difficulty with outages, unreasonably slow response times, or other technological failures, you should contact DSPS, including through the process set forth above.
As reported in previous Valued Voice stories, WHA continues to work with DSPS and its boards to provide additional clarity around the new mandate and to expedite efforts by DSPS’s vendor to implement cost and time effective options to enable federally certified EHRs to present PDMP data.
Training materials, FAQs, and additional contact information are available on the PDMP website. To view that information, go to: https://pdmp.wi.gov/training-materials.
In addition, other changes to the PDMP take effect April 1. One change shortens the time period in which applicable dispensers must submit data to the PDMP to no later than 11:59 p.m. of the next business day after the monitored prescription drug is dispensed.
Another change taking effect April 1 permits individuals who "medically coordinate, direct, supervise, or establish standard operating procedures" to receive certain PDMP data to help such individuals evaluate practitioners’ job performance or perform quality assessment or improvement activities.
Additional information about these additional changes, along with a summary of the Act’s PDMP mandate can be found in a "WHA Act Summary of Act 266, 267, and 268: Changes to Wisconsin’s Prescription Drug Monitoring Program (PDMP)" in the WHA members-only portal under the "Legal Resources – Wis. Legislative Summaries" tab. If you do not have a member account in the WHA members-only portal, go to members.wha.org and click on "Register" to create an account. If you have questions about how to register, contact Tammy Hribar at thribar@wha.org or 608-274-1820.