The CSRS was established in 2007 as an important tool for prescribers and dispensers of controlled substances, allowing them to provide safer care for their patients. The CSRS helps to combat the deaths, emergency department visits and diversion of controlled substances occurring as we experience an epidemic of prescription drug misuse. The CSRS provides a database that allows DHHS registered prescribers and dispensers of controlled substances to have Web access to review the controlled substance prescriptions their patients have received in an effort to provide safer care.
Portions of the law go into effect immediately while other portions become effective January 1, 2014. Provisions that have already become law will take time to implement and will be phased in.
Specific provisions enacted
The following provides a brief summary of the provisions. Further details will be posted on the CSRS website (www.nccsrs.org) as they become available.
- Prescribers and Dispensers may delegate the task of querying to others under their supervision provided DHHS registers and approves the delegates. The delegator must be registered with the CSRS and the delegates will be linked to the prescriber or dispenser who will be responsible for their activities and the handling of confidential information. Fines for misuse of the CSRS or information from the CSRS are increased to up to $10,000 per instance. It is important to note that the delegation is only for querying and obtaining the information. Interpreting the information continues to be the responsibility of the prescriber or dispenser.
- Physician dispensed medication in excess of a 48 hour supply must be reported to the CSRS starting January 1, 2014. This closes an information gap that currently exists. Further information on how this requirement may be met will be disseminated in the near future to Board of Pharmacy permitted dispensaries.
- Effective January 1, 2014, all required prescriptions dispensed by pharmacies and required dispensed medication must be reported to the CSRS not later than the close of business three business days after the delivery of the medication to the patient. In addition, dispensers are encouraged to report the information no later than 24 hours after the prescription is delivered. Dispensers will also be required to report the method of payment to the CSRS.
- DHHS may alert prescribers and dispensers of patients who have obtained prescriptions in a manner that may represent abuse, diversion of controlled substances, or an increased risk of harm to the patient. These “unsolicited alerts” will usually come via email and direct the practitioner to consult a specific query number in the CSRS. Although all prescribers may receive an alert, only registered prescribers will be able to view the query prepared for them in their account. Non-registered prescribers will be encouraged to register and will be provided a link to obtain an application.
- DHHS may alert licensing boards of prescribing or dispensing practices in accordance with rules established by the respective board.
- DHHS must provide information to sheriffs, designated deputy sheriff’s, police chiefs or their designated investigators assigned to investigate diversion and illegal use of prescription medications or pharmaceutical products identified as controlled substances who are engaged in a bona fide investigation and pursuant to a court order.
Independent of the recent statutory changes, the CSRS is working with the Medical Board to make it easier to register for access to the reporting system while enabling the CSRS to maintain more complete information. These improvements are currently in the developmental stages. Among them are:
- A streamlined registration process whereby a prescriber could register for Web access to the CSRS via a portal on the NCMB’s website. A notarized signature would not be required for this avenue of registration. The prescriber would sign into a secure Medical Board portal. A link would be provided for them to register for the CSRS. The plan is to ask licensees of the Medical Board for information not currently stored by the Board (such as DEA number and proposed password) but required to access the reporting system. This additional information will be combined with the information on record with the NCMB and sent electronically to the CSRS office for registration. Prior to transmitting the data the prescriber will sign the privacy statement and give consent for the transmission.
- An upgrade to the language format that pharmacies report into the CSRS is planned. (changing from ASAP 1995 to ASAP 4.2). This change will allow CSRS to capture more information including the ID of the person picking up a prescription for a Schedule II and/or Schedule III opioid analgesic.
- We are hopeful that these changes and improvements will enable more prescribers to begin using this valuable tool. Routine use of the CSRS is quickly becoming the standard of care when providing treatment that includes prescribing controlled substances.
Contact Devon Scott or William Bronson with the Department of Health and Human Services at 919-733-1765 if you have any questions.
Charts illustrating leading cause of death and unintentional deaths in NC due to controlled substances.