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The Pulse

  • Controlled Substances Reporting System Update

    On September 19, 2018, DHHS released an updated Controlled Substances Reporting System (CSRS) database.  All registered providers should have received an email directing them how to log into the new system to access the CSRS. The old site will no longer function, so you need to make sure you log into the new system to ensure continued access to the CSRS.

    CSRS Update Tips:

    • We have heard reports of PAs setting up their new profile incorrectly. When the system asks you to identify your specialty, you need to select “Physician Assistant”. If you select another specialty, the system will treat you like a physician and you will not be able to designate yourself as a PA.
    • Make sure your NPI and license number are entered and correct.
    • You shouldn’t allow anyone else to use your login.
    • If you have had challenges logging into the new system or entered erroneous data in the profile update, please email nccsrs@dhhs.nc.gov.
    • If you don’t have an account but wish to register, you can do so here. Just click “create new account.”
    • Please remember if you have any problems using the system due to technology or electrical failures the STOP Act provision states: Reviews should be documented within the patient’s medical record along with any electrical or technological failure that prevents such review. Practitioners are required to review the history and document the review once the electrical or technological failure has resolved.

    As you are aware, the STOP Act requires providers to review a patient’s 12-month prescription history in the CSRS prior to prescribing a Schedule II or Schedule III opioid or narcotic. Additionally, for as long as that controlled substance is prescribed to the patient, providers are required to review the patient’s 12-month prescription history in the CSRS every three months.

    While the effective date for this requirement has not been established, the updated system takes us one step closer to this requirement. We know many PAs are already using the system, but for those who are waiting to register until the required date is established, we encourage you to make sure you are familiar with the requirement. Below is an excerpt of summary that NCAPA provided members after the STOP act was enacted in 2017:

    Controlled Substances Reporting System Requirements

    Effective July 1, 2017

    Allows the Department of Health and Human Services to notify practitioners and the North Carolina Medical Board of prescribing behaviors that increase risk of diversion of controlled substances, increase risk of harm to patient, or is an outlier among other practitioner behavior.

     

    Requires emergency departments and hospital acute care facilities to provide the Department of Health and Human Services with a list of delegations who are authorized to receive data on behalf of providers within the facility.

    Effective TBD*

    Requires practitioners to review a patient’s 12-month history in the CSRS prior to prescribing any targeted controlled substance, and to review the patient’s 12-month history every three months thereafter, while the targeted controlled substance remains part of the patient’s medical care plan.

    All 12-month reviews must be documented in the patient’s medical records, along with the occasion of any CSRS outage that prevents a review. If an outage were to occur, the practitioner must review the 12-month history upon restoration of the CSRS.

    Does NOT require, but allows for practitioners to review the patient’s CSRS history in the following circumstances:

    1. The controlled substance is administered to a patient in a health care setting, hospital, nursing
      home, outpatient dialysis facility, or residential care facility.
    2. The controlled substance is prescribed for the treatment of cancer or another condition
      associated with cancer.
    3. The controlled substance is prescribed to a patient in hospice care or palliative care.

    Requires the Department of Health and Human Services to conduct periodic audits of review of the CSRS by prescribers and report prescribers in violation to the North Carolina Medical Board.

    *Effective 30 days after the North Carolina Chief Information Officer notifies the state Revisor of Statutes that the CSRS upgrades described in subdivisions (1) and (2) of subsection (a) of Section 12F.7 of SL 2016-94 have been completed and the upgraded CSRS is fully operational and connected to the statewide health information exchange.

    More Information about the STOP Act:

    • You can read NCAPA’s fact sheet here.
    • You can read the NCMB summary of on the STOP Act here.
    • You can read the full text of the stop at

     

     

     

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