5.3 Prospective DUR & the PA PDMP (ABC-MAP)

Prospective DUR — The Clinical Duty Before Dispensing

Prospective drug utilization review (DUR) is the pharmacist's review of a prescription before dispensing to detect and prevent drug-related problems. OBRA '90 (federal) mandates prospective DUR and an offer to counsel for Medicaid outpatients; PA is stricter — 49 Pa. Code § 27.1 and the Board's counseling standards require a DUR and a counseling offer for all patients on new prescriptions, regardless of payer.

The DUR elements the pharmacist must screen for, as defined in 49 Pa. Code § 27.1 and consistent with federal OBRA '90, include:

• Therapeutic duplication — two drugs in the same therapeutic class (e.g., two NSAIDs, two SSRIs).
• Drug-disease contraindications — e.g., NSAIDs in advanced CKD, beta blockers in severe asthma.
• Drug-drug interactions — e.g., SSRI + tramadol (serotonin syndrome), warfarin + azole antifungal.
• Inappropriate dose or duration — outside evidence-based limits, including PA's 7-day opioid limits under Act 122 of 2016 (ED/urgent care/observation) and Act 125 of 2016 (minors).
• Allergy or cross-allergy — documented allergy to the drug or class.
• Abuse or misuse — quantities, refill pattern, or behavior suggesting diversion or substance use disorder.

If the DUR reveals an issue, the pharmacist must resolve it (contact the prescriber, adjust documentation, or refuse) before dispensing and document the resolution.

The PA PDMP — ABC-MAP

The Achieving Better Care by Monitoring All Prescriptions Program (ABC-MAP) is Pennsylvania's Prescription Drug Monitoring Program. It was created by Act 191 of 2014 and is operated by the PA Department of Health (DOH). Reporting became mandatory in August 2016, and the PDMP query requirement took effect January 1, 2017.

Dispenser reporting duties

A "dispenser" — any pharmacy or practitioner who dispenses controlled substances in or into Pennsylvania — must submit dispensing data to ABC-MAP for all Schedules II–V prescriptions. Submissions must be made by the close of the next business day after dispensing. Data elements include patient identifiers, prescriber, drug, quantity, days supply, and method of payment. Pharmacies should use the DOH-approved reporting portal (PMP AWARxE) and reconcile failures promptly.

Prescriber and dispenser query triggers

The MPJE frequently tests when a query is required, and Pennsylvania distinguishes prescriber duties from dispenser (pharmacist) duties under Act 191 of 2014 (as amended by Act 124 of 2016), effective January 1, 2017:

Prescriber query triggers

1. The first time a controlled substance is prescribed to a patient (baseline medical record).
2. When the prescriber has a reasonable belief the patient may be abusing, misusing, or diverting.
3. Each time an opioid or benzodiazepine is prescribed.

Dispenser (pharmacist) query triggers

Dispensers must query ABC-MAP before dispensing an opioid or benzodiazepine if any of the following apply:

1. The patient is a new patient to the pharmacy (records unavailable at that pharmacy/chain location).
2. The patient pays cash despite having insurance (cash = any non-insurance payment excluding copays).
3. The patient requests an early refill (>15% of prior supply remaining, or before insurance eligibility).
4. The patient is receiving opioids/benzodiazepines from more than one prescriber.

There is no general “≤7-day supply” query exemption for outpatient dispensing in Pennsylvania.

Statutory exemptions

The query requirement does not apply to:

• A patient receiving hospice care, palliative care, or treatment for a terminal illness.
• A patient receiving a controlled substance while an inpatient of a licensed health care facility.
• Controlled substances administered directly to a patient in a health care facility or by a licensed practitioner.
• Veterinarians dispensing for animal treatment.

Note the asymmetry: reporting has broader scope than querying. A 5-day opioid prescription for an outpatient must still be reported to ABC-MAP by the next business day even though the query is exempt.

Interstate data sharing

ABC-MAP is connected to PMP Interconnect, sharing data with 30+ states as of 2026. A PA pharmacist querying ABC-MAP may see controlled-substance fills the patient obtained in participating neighboring states (NJ, NY, OH, MD, WV, DE, and others). Cross-state "doctor shopping" is therefore visible to the PA pharmacist — a fact MPJE questions often hinge on.

DUR, PDMP, and Corresponding Responsibility Together

The three duties operate together. Prospective DUR is the clinical screen. ABC-MAP is the data source the pharmacist uses to evaluate one DUR element — abuse/misuse — for controlled substances. Corresponding responsibility under 21 CFR § 1306.04 is the legal backstop. A pharmacist who fails to query ABC-MAP when a trigger is present has not only violated Act 191 but has also failed to perform a complete DUR, weakening any defense to a corresponding-responsibility charge.

Common MPJE traps

• "The PDMP only applies to opioids." — No. ABC-MAP reporting covers Schedules II–V, including stimulants, benzodiazepines, sedative-hypnotics, anabolic steroids, and certain other products.

• "PA pharmacists don't have to query because only prescribers do." — No. Act 191 places the query duty on both prescribers and dispensers when triggered.

• "The PDMP is run by the Board of Pharmacy." — No. ABC-MAP is operated by the PA Department of Health. The Board of Pharmacy enforces related pharmacy practice rules, but DOH administers the PDMP.

• "Hospice exempts the patient from reporting." — Hospice exempts the query, not the report; the dispense is still reported to ABC-MAP.