CSR holders in EDs, pain clinics also must start INSPECT queries on Jan. 1

Jan. 1, 2019, is an important legal deadline for some Indiana physicians, after the General Assembly passed SEA 221 during the 2018 session.

First, any provider holding a controlled substance registration (CSR) in Indiana must be registered with INSPECT, the state’s prescription drug monitoring program, by Jan. 1, 2019. CSR holders may register with INSPECT here, at no charge. Before you begin, you will need to have  handy: an individual email address only you, the physician, can access; your CSR number; your DEA number; your medical license number; and your driver's license number.

Second, starting Jan. 1, 2019, CSR holders in a hospital emergency department (ED) or a pain clinic must query INSPECT records every time they prescribe or dispense an opioid or benzodiazepine. This requirement will be phased in for CSR holders in other practice settings over the next two years. Integrating EHRs with INSPECT is not necessary to be able to query INSPECT; providers will always be able to do this online at https://indiana.pmpaware.net/login. 

Failure of a CSR holder to register with INSPECT by Jan. 1, 2019, or to perform the queries as required, will constitute a Class A misdemeanor.

Here are answers to some key questions about the new law.

Q. Who must register with INSPECT by Jan. 1, 2019?
A. If you hold a CSR, you must register by the deadline. The law applies to any physician, hospital, researcher or other provider who holds a CSR to prescribe, distribute or dispense controlled substances in Indiana.

Q. Will I have to check INSPECT when prescribing or dispensing all controlled substances?
A. No. The new law applies only for opioids and benzodiazepines.

Q. When do CSR holders have to start querying INSPECT?
A. That depends. In a setting with INSPECT integration, you must already be querying INSPECT whenever you prescribe opioids or benzodiazepines. CSR holders in the following settings must begin making the queries by these dates:

• Jan. 1, 2019: Practitioners who provide services to the patient in a hospital emergency department or a pain management clinic. The law defines a pain management clinic as a publicly or privately owned facility that primarily engages in the treatment of pain or management through prescribing controlled substances. It does not refer to hospice, outpatient surgical centers or long-term care facilities.
• Jan. 1, 2020: Practitioners who provide services to the patient in a hospital.
• Jan. 1, 2021: All  remaining Indiana practitioners.

Q. Do I have to query INSPECT every time I prescribe or dispense an opioid or benzodiazepine?
A. Yes, with one exception. If a patient is subject to a pain-management contract, INSPECT information needs to be obtained only once every 90 days. Also, the requirement applies for all patients, including infants and those in hospice, palliative or long-term care.

Q. What if I have no internet access or only unreliable access?
A. These CSR holders may receive a waiver under a process to be established by the Indiana Board of Pharmacy.

Q. What if I’m too busy to query INSPECT?
A. A delegate may perform the queries on your behalf. Also, integrating your facility’s EHRs with INSPECT reduces the time to search patients’ records from about five minutes using the online portal to two or three seconds. Integration is fast, simple and free, thanks to the state’s decision last year to fund these costs. To begin the integration process, visit www.ismanet.org/INSPECTintegration.

Two PowerPoint slides explaining SEA 221 may help in understanding its requirements; those are available here.