Monday, August 26th, 2013
PHYSICIANS DUTY TO CONSULT THE PRESCRIPTION MONITORING PROGRAM IS REQUIRED ON TUESDAY, AUGUST 27, 2013.
The “duty to consult” the Prescription Monitoring Program (PMP) is effective on Tuesday, August 27, 2013 and requires prescribers to review a patients’ prescription history prior to issuing a prescription for Schedule II, III or IV drug.
You have submitted an application for a Health Commerce System (HCS) but have not yet received approval or a password to reactivate your account. Can I still prescribe for patients on August 27, 2013?
DOH realizes that there is a backlog. The Department of Health has put in considerable resources to working with the Health Commerce System (HCS) staff. The NYS Bureau of Narcotic Enforcement (BNE) has paid for a number of temporary employees and staff members to handle the backlog. A large part of the backlog has been addressed and accounts are being processed at a faster rate.
Anyone who has made good faith efforts to apply for HCS account, but has not yet received approval or a password; the NYS Bureau of Narcotic Enforcement (BNE) is not asking that person to avoid the treatment of their patients. BNE will not carve out a waiver period. However, before BNE seeks enforcement, BNE will know if you tried to apply. You will need able to document that you submitted an application, made phone calls, etc. As long as you are making reasonable efforts to obtain your HCS account and continue to do so, please continue to treat your patients. If possible, have a prescriber who already has an account in your practice, access the PMP until you receive your account.
If you have an established Health Commerce System (HCS) account; follow these directions to access the Prescription Monitoring Program (PMP) Registry on August 27, 2013
To access the Prescription Monitoring Program (PMP) registry go to the Health Commerce System at:
2) Log onto the system with your user ID and password (If you can’t remember your password, call the Commerce Account Management Unit at 1-866-529-1890, Option 1 for assistance)
3) Select “Applications” at the top of the page. Click on the letter “P”.
4) Scroll down to the Prescription Monitoring Program Registry.
5) Click the green plus sign under the Add/Remove column to add this application to your “Favorites” so you don’t have to scroll down each time in the HCS (optional)
6) Click to open the program
7) Enter all required information and Review the Frequently Asked Questions with the application for further information
Should you or your designee encounter technological difficulties or have questions regarding accessing the PMP, please contact the New York State Department of Health Commerce Account Management Unit at 1-866-529-1890, option 1 for assistance or the Bureau of Narcotic Enforcement at 1-866-811-7957.
Don’t have a Health Commerce System (HCS) account?
Steps to begin registration:
Physicians and their selected designees who have not yet established an account should begin the process immediately as you cannot access the PMP registry without an account. To obtain an account please go to the New York State website at:
2) Click on Apply for an HCS Medical Professions account to apply for a Health Commerce System (HCS) account for prescribing and non-prescribing medical professionals.
Please go to the MSSNY website for step by step instruction on how to establish a Health Commerce System account at www.mssny.org. The process to obtain an HCS account takes about two weeks.
Would you like to designate your office staff to look up patients? If your answer to this question is YES, please read the following:
Physicians can designate office staff to look up patients but the designee must also have a HCS account. They can sign up by following the instructions above. Once the designee has an HCS account, the physician will need to designate them in the PMP. Physicians will need to log onto the PMP and click on the blue tab that says designate. Physicians then can list the names of their designees. Designees may begin to look up patients since the regulations were adopted on August 21, 2013.
Physicians and staff are also encouraged to go the NYS DOH Bureau of Narcotic Enforcement’s website for additional information:
Do you have a Health Commerce Account but haven’t used it within the past ninety days and need a new password? Read below:
Passwords expire after 90 days, therefore, if you have not used your account in the last 90 days, your password will have expired. To reestablish your password, contact the New York State Department of Health Commerce Account Management Unit (CAMU) at 1-866-529-1890.
NYS Commerce Account Management Unit- hours of operation:
The Department of Health has indicated that the CAMU unit will be opened until August 27, 2013 from 8 a.m. to 7 p.m. and will be opened this weekend from 9 a.m. to 12 noon to provide assistance to physicians who are seeking to set up an HCS account or to obtain a password for existing accounts. Physicians can call the CAMU at 1-866-529-1890. DOH has indicated that that the physician himself or herself must be on the phone –administrative staff is not authorized to establish an HCS Account or reactivate an account on behalf of a physician.
MSSNY recommends that all physicians begin documenting their calls to the CAMU unit, the length of time on the phone, etc., and maintain these records as MSSNY has been informed that there is a backlog.
What if I don’t comply with the law?
Failure to comply with the law may result in fines, jail time and loss of licensure.
Frequently Asked Questions for NYS PMP and Drug Schedule
The Department of Health Prescription Monitoring Program contains a list of frequently asked questions (FAQs) concerning the PMP and the Schedule for II, II or IV drugs. Physicians and their designees can access this directly from the PMP or the FAQs and schedule for drugs is also available on the MSSNY website at www.mssny.org.
Who established the “duty to consult” requirement?
The “duty to consult” requirement was the result of the passage of a law in 2012 called ISTOP. Chapter 447 of the Laws of 2012 amended Public Health Law Article 33, the New York State Controlled Substances Act, and requires most practitioners in New York State to check New York’s Prescription Monitoring Program (PMP) Registry prior to prescribing a controlled substance in Schedules II, III, and IV. This law requires prescribers to review information in the PMP database on their patients’ prescription history. The law also requires pharmacists to enter the prescription into a database called the Prescription Monitoring Program (PMP). Pharmacies have the obligation under the law to enter the prescription into the database within 24 hours.
The law also requires e-prescribing of all prescriptions, including controlled substances, by March 27, 2015. Please check the MSSNY website periodically for any future updates on this law.
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Tuesday, November 8th, 2011
The American Medical Association (AMA) has advised local medical societies and physicians that they have met with the Centers for Medicare & Medicaid Services (CMS) regarding the enrollment revalidation process. In their letter the AMA stated that the CMS director agreed to extend the provider enrollment revalidation process through 2015.
CMS has indicated in the Medicare Learning Network (MLN) Matters Special Edition (SE) article SE1126, that it may be appropriate to delay; however there has been no delay to 2015 that has been formally announced by CMS. If CMS were to delay the final compliance date of revalidation into 2015, the process will still continue.
If you have received a revalidation request letter from National Government Services you are still required to complete your enrollment forms for revalidation and return them to National Government Services within 60 days from the date of the letter as the letter indicates. National Government Services is working toward sending the second letter soon. If you receive a letter during that phase you will also need to comply within 60 days from the date of the letter and revalidate your provider number by sending in a fully completed CMS-855. Failure to do so may lead to deactivation of your Provider Transaction Access Number (PTAN) and billing privileges to Medicare.
Note: Please remember that the revalidation process does not change or alter normal provider enrollment laws for Medicare. If you have a change of address, reassignments, additions to practice, changes in authorized officials or other information updates you are still required to submit that change within 30 days. You cannot wait for revalidation to update your enrollment record. That is not in compliance with Medicare regulation.
- CMS has not delayed any timeframes in the revalidation process.
- If you receive a revalidation letter you must submit your fully completed application within 60 days from the date of the letter.
- Failure to reply to the revalidation request may lead to suspension of Medicare billing.
- If a change occurs, you must update the information to your enrollment record
For more information about the enrollment process and required fees, refer to MLN Matters article MM7350, which is available at: http://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf on the CMS Web site.
For more information about the application fee payment process, refer to MLN Matters article SE1130, which is available at http://www.cms.gov/MLNMattersArticles/downloads/SE1130.pdf on the CMS Web site.
The MLN fact sheet titled “The Basics of Internet-based Provider Enrollment, Chain and Ownership System (PECOS) for Provider and Supplier Organizations” is designed to provide education to provider and supplier organizations on how to use Internet-based PECOS to enroll in the Medicare Program and can be found at http://www.cms.gov/MLNProducts/downloads/MedEnroll_PECOS_ProviderSup_FactSheet_ICN903767.pdf on the CMS Web site.
To access PECOS, your Authorized Official must register with the PECOS Identification and Authentication system. To register for the first time go to https://pecos.cms.hhs.gov/pecos/PecosIAConfirm.do?transferReason=CreateLogin to create an account.
National Government Services, Inc.
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Friday, November 12th, 2010
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