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Three New Requirements for Prescription Drugs In Effect

If you prescribe or dispense medication in New York, you must be aware of three important changes effective on March 30th and August 27, 2013, and March 27, 2015:

1. Patient English Language Proficiency – Effective March 30, 2013

As of March 30, 2013, all prescriptions must indicate whether a patient lacks proficiency in English and, if so, the language in which they are proficient. New prescription forms are available at no charge from the NYS Department of Health. Alternately, the prescriber may simply note on the prescription that a patient is not proficient in English and the language of proficiency. If the patient is English proficient no further action is necessary.

2. Controlled Substance Registry – Effective August 27, 2013

As of August 27, 2013, all doctors prescribing or dispensing a Schedule II, III, or IV controlled substance in any quantity must query a new controlled drug Registry. To access the Registry, you must establish an online Health Commerce System (HCS) account. (see below) All doctors who directly dispense any controlled substance in any Schedule in any quantity to a patient must input into the registry the information concerning the controlled drug they directly dispensed to that patient.

Setting up HCS Account Guides:

Health Commerce System (HCS) Account for Licensed Medical Professionals

How to Access the Prescription Monitoring Program (PMP) Registry

Health Commerce System (HCS) Account for Unlicensed Professionals

3. Mandatory E-Prescribing – Effective March 27, 2015

Beginning March 27, 2015, all prescriptions, including all controlled substances, must be transmitted electronically – paper prescriptions will no longer be acceptable (there are extremely rare exceptions not generally applicable for most dentists).

New York’s I-STOP legislation establishes new requirements for all doctors prescribing a Schedule II, III, or IV controlled substance or dispensing any controlled substance in any Schedule in any quantity. The NYS Department of Health (DOH) has begun establishing a Prescription Monitoring Program Registry (the Registry). The Registry is designed to curb abuse of prescription controlled drugs. The Registry is scheduled to go into effect on August 27, 2013. In order to prescribe or dispense any Schedule II, III, or IV controlled substance after August 27, 2013, you must be able to access the Registry.

Beginning on August 27, doctors must consult the Registry before prescribing any Schedule II, III, or IV drug to a patient. The Registry will contain a minimum of a six month patient controlled substance history and a maximum of a five year history that the prescriber can review. The I-STOP law does allow for a health care professional to designate a person to access and consult the Registry on his or her behalf – but the health care professional always remains legally responsible for the result and conduct of that process by the designee.

Pharmacists will input information from all the controlled substance prescriptions they fill. Any health care provider who actually dispenses any controlled substance on any Schedule to a patient, in any quantity, will also be obligated to input that drug dispensing information into the Registry.

Prescribers will access the Registry through the Health Commerce System (HCS) online account that they already use for renewing and issuing official New York State prescription forms. While many dentists now opt to do those renewals via paper, the only way you will be able to access the Registry is via the HCS online account system.

If you fail to sign up for the Registry, you will lose the ability to prescribe any Schedule II, III, or IV controlled substance, as well as the ability to dispense any controlled substance directly to a patient. Your license to practice will also be at risk from the Office of Professional Discipline (OPD) if you attempt to evade or violate the Registry system.

For further information on the HCS online account system, go to: or call the HCS account system at either: 866-529-1890, option 1; or 866-811-7957, option 1. They can also answer your questions about the Registry as it progresses toward the August 27, 2013, go-live date.