10.2 Oklahoma Prescription Monitoring Program (OK PMP / PMP AWARxE)

10.2 Oklahoma Prescription Monitoring Program (OK PMP / PMP AWARxE)

The Oklahoma Prescription Monitoring Program (OK PMP), operating on the PMP AWARxE platform, is a statewide electronic database that tracks the prescribing and dispensing of Controlled Dangerous Substances (CDS). Established under the Oklahoma Anti-Drug Diversion Act (Title 63 O.S. § 2-309A through § 2-309H) and administered by the Oklahoma Bureau of Narcotics and Dangerous Drugs Control (OBNDD; OAC Title 475, Chapter 45), the OK PMP serves as a frontline technological weapon against prescription drug misuse, diversion, doctor-shopping, and opioid-related morbidity.

Understanding the precise legal responsibilities associated with the OK PMP—including dispenser reporting deadlines, mandatory prescriber querying triggers, pharmacist corresponding responsibility, authorized delegate supervision, and strict confidentiality protections—is essential for pharmacy practice in Oklahoma.

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Dispenser Reporting Requirements: Title 63 O.S. § 2-309C

Every pharmacy, nonresident pharmacy licensed to ship into Oklahoma, and dispensing practitioner that dispenses a controlled substance to an outpatient in Oklahoma must electronically submit dispensing data to the OK PMP.

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|                        OK PMP DISPENSER REPORTING MANDATES                              |
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| Parameter                   | Statutory Requirement                                     |
|-----------------------------|-----------------------------------------------------------|
| Covered Schedules           | Schedules II, III, IV, and V Controlled Substances        |
| Submission Deadline         | WITHIN 5 MINUTES of dispensing (OAC 475:45-1-5)           |
| Zero-Reporting Rule         | Mandatory "Zero Report" if no CDS dispensed on open day   |
| Format                      | ASAP (American Society for Automation in Pharmacy) standard|
| Administrative Agency       | Oklahoma Bureau of Narcotics (OBNDD)                      |
+-----------------------------------------------------------------------------------------+

1. The Five-Minute Real-Time Submission Deadline

Oklahoma pioneered real-time PMP reporting and its deadline is far tighter than most states'. OAC 475:45-1-5 provides that the required information "must be reported to the central repository within five (5) minutes of the time that the controlled dangerous substance is dispensed." The underlying statute, 63 O.S. § 2-309C(B), originally set a 24-hour deadline but directed that beginning January 1, 2012 all information be submitted on a real-time log — the five-minute rule implements that. This is the single most commonly missed Oklahoma PMP fact, because the national norm is 24 hours or next business day. The transmission uses the ASAP (American Society for Automation in Pharmacy) telecommunications format designated by OBNDD and covers each dispensation the date the medication was dispensed.

2. Mandatory "Zero Reports"

If a licensed pharmacy is open for business on a given operating day but dispenses zero (0) controlled substance prescriptions in Schedules II through V, the pharmacy is legally required to submit an electronic "Zero Report" to the OK PMP repository. Failing to submit either dispensing logs or zero reports exposes the pharmacy to administrative fines and disciplinary action by the Board of Pharmacy and OBNDD.

3. Required Data Elements

For each controlled substance dispensed, the dispenser must submit the following comprehensive data fields:

• Patient Information: Full legal name, date of birth (DOB), residential address (including ZIP code), and gender.
• Prescriber Information: Full name, DEA registration number, and National Provider Identifier (NPI).
• Dispenser Information: Pharmacy DEA registration number, NPI, and physical location.
• Prescription Details: Prescription number (Rx #), date the prescription was written/issued, and date the prescription was filled/dispensed.
• Drug Product Details: National Drug Code (NDC), exact metric quantity dispensed, estimated days supply, and refill number.
• Method of Payment: Specific payment code (e.g., cash, private commercial insurance, Medicaid / SoonerCare, Medicare Part D, workers' compensation).

4. Exemptions from Dispenser Reporting

Dispenser reporting to the OK PMP is NOT required for:

• Direct administration of a controlled substance to an inpatient in a licensed hospital, hospice facility, or ambulatory surgical center.
• Dispensing by a licensed drug room or institutional pharmacy within a correctional institution for immediate inmate administration.
• Wholesale distribution of CDS between registered manufacturers, distributors, or pharmacies (tracked separately under DEA ARCOS and state wholesale reporting).

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Mandatory Prescriber Query Requirements: Title 63 O.S. § 2-309D

To curb excessive prescribing and identify multi-provider ordering, Oklahoma law imposes strict, mandatory querying obligations on prescribing practitioners:

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|                    MANDATORY PRESCRIBER OK PMP QUERY TRIGGERS                           |
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| Clinical Scenario                        | Legal Obligation                             |
|------------------------------------------|----------------------------------------------|
| Initial Opioid Analgesic Prescribing     | MANDATORY query prior to issuing order       |
| Initial Benzodiazepine Prescribing       | MANDATORY query prior to issuing order       |
| Continued therapy (opiate/benzo/carisoprodol) | MANDATORY check if 180 DAYS have elapsed |
| Inpatient Hospital / ER (< 72-hr supply) | EXEMPT from mandatory query                  |
| Hospice / Terminal Cancer Care           | EXEMPT from mandatory query                  |
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1. The Opioid and Benzodiazepine Triggers

Under Title 63 O.S. § 2-309D, prior to prescribing any opioid analgesic or benzodiazepine to a patient, the prescriber must query the OK PMP database to review the patient's controlled substance dispensing history.

2. The 90-Day Chronic Treatment Mandate

If the patient continues on ongoing therapy with an opioid analgesic or benzodiazepine, the prescriber must check the OK PMP at least once every ninety (90) days (or at least quarterly) during active treatment. The prescriber must document the PMP review in the patient's medical record.

3. Statutory Exceptions to Prescriber Querying

A prescriber is exempt from querying the OK PMP only under specific, narrow statutory circumstances:

• When prescribing for a patient receiving active hospice or palliative care for a terminal illness.
• When prescribing for a patient with an active cancer diagnosis receiving oncology management.
• When administering a controlled substance directly to an inpatient in a hospital, hospice, or long-term care facility.
• In an emergency room setting when dispensing or prescribing a quantity of not more than a seventy-two (72) hour emergency supply.

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Pharmacist Querying & Corresponding Responsibility

While prescribers have rigid 90-day statutory triggers for opioids and benzodiazepines, Oklahoma pharmacists bear a continuous, legal "Corresponding Responsibility" under Title 63 O.S. § 2-309 and 21 CFR § 1306.04 to ensure that every controlled substance prescription is issued for a legitimate medical purpose in the usual course of professional practice.

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|             PHARMACIST OK PMP RED FLAGS REQUIRING MANDATORY INQUIRY                     |
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| 1. High MME Thresholds    | Total daily opioid dose exceeds 90 Morphine Milligram       |
|                           | Equivalents (MME/day).                                      |
| 2. "The Holy Trinity"     | Dangerous combination: Opioid + Benzodiazepine + Muscle     |
|                           | Relaxant (e.g., Oxycodone + Alprazolam + Carisoprodol).     |
| 3. Multi-Provider Pattern | Patient obtaining CDS from ≥3 prescribers or ≥3 pharmacies  |
|                           | within a rolling 90-day window (Doctor/Pharmacy Shopping).  |
| 4. Geographic Anomalies   | Significant geographic distance between patient home,       |
|                           | prescriber clinic, and dispensing pharmacy.                 |
| 5. Early Refill Requests  | Attempts to obtain refills prior to using ≥85-90% of supply |
|                           | or abrupt shifts from insurance to cash payments.           |
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Clinical PMP Evaluation Protocols for Pharmacists:

1. Red Flag Investigation: When an OK PMP report reveals concurrent sedatives, high MME scores, or overlapping fill dates, the dispensing pharmacist must not turn a blind eye. The pharmacist must contact the prescriber, verify the clinical rationale, assess for naloxone co-prescribing, and document the resolution in the pharmacy system before dispensing.
2. PMP InterConnect (Interstate Data Sharing): Through the NABP PMP InterConnect network, Oklahoma pharmacists can seamlessly review PMP dispensing data from bordering states (Texas, Arkansas, Missouri, Kansas, Colorado, New Mexico) to detect cross-border doctor shopping.

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Authorized Users, Delegate Rules & Data Confidentiality

Because the OK PMP repository contains highly sensitive Protected Health Information (PHI) and prescription histories, access is strictly regulated:

1. Authorized Users

• Licensed Prescribers: Physicians (MD/DO), dentists (DDS/DMD), podiatrists (DPM), optometrists (OD), veterinarians (DVM), physician assistants (PA), and advanced practice registered nurses (APRN) with active DEA and OBNDD registrations.
• Licensed Pharmacists: Oklahoma-licensed pharmacists actively engaged in dispensing or prospective drug utilization review.
• Designated Delegates: A licensed prescriber or licensed pharmacist may authorize designated delegates (such as registered pharmacy technicians, medical assistants, or nurses) to access the PMP on their behalf. However:
  • The delegate must register for an individual user account and complete required security training.
  • The delegating professional remains legally accountable for all searches conducted by the delegate.
  • The licensed professional must personally review and evaluate the clinical data retrieved by the delegate.
• Law Enforcement & Regulatory Officials: OBNDD agents and certified law enforcement officers may access PMP data ONLY in connection with a bona fide, open criminal or regulatory investigation. The Oklahoma State Board of Pharmacy and medical licensing boards may access records pursuant to a formal disciplinary complaint.

2. Confidentiality & Legal Immunity (Title 63 O.S. § 2-309D)

• Non-Public Privilege: OK PMP data is strictly confidential, privileged, and exempt from the Oklahoma Open Records Act. It cannot be disclosed in response to public records requests or civil discovery subpoenas without a specific court order issued by a judge with competent jurisdiction.
• Statutory Immunity: Prescribers and pharmacists who access, review, or submit data to the OK PMP in good faith are granted complete statutory civil immunity from liability in any civil action arising from their reporting or query activities.

3. Criminal Penalties for Misuse

Any person who knowingly or intentionally accesses the OK PMP without statutory authorization, uses PMP data for personal curiosity (e.g., searching friends, family members, or public figures), or discloses PMP information to unauthorized third parties is guilty of a criminal offense (felony or misdemeanor under Title 63 O.S. § 2-309D), punishable by substantial criminal fines, imprisonment in the state penitentiary, and immediate disciplinary revocation of professional licensure.