8.1 MassPAT: Prescription Monitoring Program Query & Reporting

MassPAT: Prescription Monitoring Program Query & Reporting

The Massachusetts prescription monitoring programme is administered by the DPH Drug Control Program and is known as MassPAT — the Massachusetts Prescription Awareness Tool. Its statutory basis is M.G.L. c. 94C, § 24A, and the operating rules are at 105 CMR 700.012, with the Board's parallel provisions at 247 CMR 5.04 and 247 CMR 20.04.

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Participation

Section 24A requires all professionals licensed to prescribe or dispense controlled substances to participate in the programme. In practice, registration is tied to the MCSR: practitioners and pharmacists obtain and maintain a MassPAT account as part of holding a Massachusetts controlled substances registration.

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The Mandatory Query — read the trigger carefully

"Participants shall utilize the prescription monitoring program each time a prescription for a narcotic drug that is contained in schedule II or III, or a prescription for a benzodiazepine, is issued."

Three observations are worth more than any mnemonic:

1. The trigger is issuance. The duty in § 24A attaches when a prescription is issued, which locates it primarily with the prescriber. A pharmacist is a participant in the programme, but the statutory event described is the writing of the prescription.
2. The drug classes are narrow and specific. Schedule II narcotics, Schedule III narcotics, and benzodiazepines. Not every Schedule II drug — a stimulant is not a narcotic. Not every controlled substance.
3. The Department may extend it. Section 24A allows the Department to require queries for any Schedule IV or V prescription drug that is commonly misused, and it directs the Department to study the feasibility of extending the programme to Schedule VI drugs generally — which is why gabapentin, a Schedule VI drug of concern, is reportable while Schedule VI at large is not.

[!IMPORTANT] Where the pharmacist's real duty comes from. A pharmacist's obligation to consult MassPAT is best understood not as a stand-alone tick-box but as part of two duties that already exist: the prospective drug utilization review required before dispensing (247 CMR 9.00), and corresponding responsibility under 21 CFR 1306.04. When a red flag is present — cash payment for high-strength opioids by an insured patient, multiple prescribers, early refills, an implausible distance, a concurrent opioid–benzodiazepine–muscle relaxant combination — a PMP query is the obvious tool for resolving it, and failing to use it is difficult to defend.

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Pharmacy Reporting

What must be reported

Every pharmacy registered with the Commissioner that dispenses a controlled substance in Schedules II through V on a prescription, and gabapentin, must report. Any pharmacy in another state, commonwealth, district or territory that delivers such a controlled substance to a person in Massachusetts is equally bound.

[!WARNING] Gabapentin is the Massachusetts signature. Gabapentin is a Schedule VI drug that the Commissioner has designated a drug of concern, and its dispensings must be reported to MassPAT alongside Schedules II through V. It is the single most commonly tested Massachusetts PMP fact, and it exists because gabapentin potentiates opioid respiratory depression.

How fast

Information must be reported to MassPAT through the PMP Clearinghouse within 24 hours, or the next business day following the most recent transmission. Section 24A itself requires submission at least once every 24 hours.

What is transmitted

Submissions follow the ASAP standard and identify the patient, the prescriber, the pharmacy, the product (NDC, quantity, days supply), the prescription number, the date written and the date filled, and the method of payment.

Consequences of failure

247 CMR 20.04(2) makes non-compliance with 105 CMR 700.012 grounds for formal disciplinary action by the Board against the pharmacist or the pharmacy, in addition to any action by other state and federal agencies.

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Delegates

A prescriber or pharmacist may authorise delegates to run queries. The rules are strict and practical:

• each delegate must hold his or her own MassPAT account, linked to the supervising participant;
• account sharing is prohibited — a delegate may never log in with a pharmacist's credentials; and
• the supervising pharmacist reviews the report and makes the dispensing decision. Delegation moves the keystrokes, not the professional judgement.

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Confidentiality

PMP data is confidential. Accessing MassPAT for a purpose unrelated to patient care — looking up oneself out of curiosity, a family member, an employee, a neighbour or a public figure — is unlawful and exposes the user to loss of PMP access, Board discipline including suspension or revocation, and prosecution.

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Worked Traps

• A pharmacy dispenses gabapentin 300 mg and does not transmit it to MassPAT because gabapentin is not federally scheduled. Violation — gabapentin is expressly reportable in Massachusetts.
• A technician runs a MassPAT query on the pharmacist's login while the pharmacist verifies prescriptions. Violation — the delegate must use his or her own account.
• A pharmacist prints a MassPAT report, does not read it, and dispenses. The query has been run and the duty has not been discharged; the point of the query is the pharmacist's review of the data before deciding.
• A mail-order pharmacy in Ohio ships hydrocodone to a patient in Springfield and reports only to Ohio's PMP. Violation — an out-of-state pharmacy delivering into Massachusetts must report to MassPAT.