You may have heard that as of January 1, 2018, Illinois veterinarians were required to register with the Illinois Prescription Monitoring Program (PMP). The obligation to register is mandatory and you can expect your professional license to practice veterinary medicine to be publicly disciplined if you fail to do so. In addition to registering, the law now requires a veterinarian to also consult the PMP “to assess patient access to controlled substances” whenever an initial script is written for any Schedule II narcotic.
You should know that this law does not apply to narcotic prescriptions for cancer treatment, palliative care, or a seven day or less supply provided by a hospital emergency department when treating an acute, traumatic medical condition.
Accordingly, you are required to check the controlled substance patient record in the PMP. You are probably also required to check the controlled substance record of the owner as well, but there is not yet any clear authority on which to rely. Although veterinarians have no clinical training in assessment or diagnosis of human addiction, you would be expected to exercise clinical judgement as to whether it is appropriate to write a Schedule II prescription.
If you feel frustrated, you have every right to feel that way. IDFPR has provided no clarification or guidance as to how these new requirements are meant to apply to practicing veterinarians. Must you truly check the PMP for both the animal and owner names? How does the PMP help you assess patient access to controlled substances if reporting is only done for the animal? If you are licensed in other states, you may already be aware that multiple states requiring all dispensers to report also specifically exempt veterinarians from that reporting.
IDFPR and the PMP have not yet provided information on how the prescription history data contained in the PMP should guide dispensing practices.We will actively monitor ongoing IDFPR enforcement efforts to see if any clarity is forthcoming. Also, do not forget to document in the patient record every time that you consult the PMP. Documenting the PMP inquiry is now required by statute.
Finally, effective January 1, 2019, all licensed Illinois controlled substance prescribers were required to complete three continuing education hours during the prerenewal period. The education must address “safe opioid prescribing practices”, and you may count these hours towards your total continuing education hours required for renewal of your practice license.
If a problem arises with your use of the PMP, Williams & Nickl is here to help you. Our firm focuses on professional license defense of veterinarians and vet technicians.