The Controlled substance Utilization Review and Evaluation System (CURES), California’s Prescription Drug Monitoring Program (PDMP) maintained by the Department of Justice (DOJ), is a database of Schedule II, III and IV controlled substance prescriptions dispensed in California.
CURES Version 2.0 tracks all Schedule II, III, and IV controlled substances dispensed in California. It contains the following information: patient name, patient date of birth, patient address, prescriber name, prescriber DEA number, pharmacy name, pharmacy license number, date prescription was dispensed, prescription number, drug name, drug quantity and strength, and number of refills remaining.
Access to CURES 2.0 is limited to licensed prescribers and pharmacists for patients in their direct care; and to regulatory oversight agency board staff and law enforcement personnel for official oversight or investigatory purposes.
Senate Bill 492 added provisions to California’s Health and Safety Code which requires a health practitioner to consult CURES in prescribing a Schedule II, III, of IV controlled substance for the first time and at least once every 4 months thereafter if the patient is still using the substance. The requirement was to go into effect six months after the Department of Justice certified that the CURES database was ready for statewide use, which they did as of April 2, 2018.
Therefore, mandatory CURES consultation
is required by October 2, 2018.
What is the CURES System?
CURES has a stated purpose to reduce prescription drug abuse and diversion without affecting legitimate medical practice or patient care.
The CURES system has provided prescribers and dispensers with Schedule II – IV prescription data via an online web portal since 2009. CURES allows authorized physicians, law enforcement, and regulatory agencies to view information on Schedule II – IV controlled substances dispensed to patients in California. Pharmacists and direct dispensers are required to report information on all Schedule II – IV controlled substances dispensed, and must upload information into CURES within seven days of dispensing.
The CURES system can be an extremely helpful tool for physicians or other dispensers who are prescribing controlled substances. A dispenser can use this information for multiple purposes, including identifying a patient who may be “shopping” multiple physicians, by viewing medications dispensed to the patient that were prescribed by other physicians, and/or providing a complete picture of Scheduled drugs dispensed to a patient. The Medical Board’s newly revised Guidelines for Prescribing Controlled Substances for Pain emphasizes that physicians should use the CURES Prescription Drug Monitoring Program (PDMP) to identify patients who obtain drugs from multiple sources as part of the Patient Evaluation and Risk Stratification process. These Medical Board Guidelines also recommend that physicians document, in their medical records, that they requested a Patient Activity Report (PAR) from CURES and the outcome of such report.
Upgrading CURES: CURES 2.0
The Department of Justice (DOJ) upgrade of CURES to CURES 2.0 enhances the information that a prescriber or dispenser can obtain from the system. In addition to the functionality of the prior system, CURES 2.0 provides an improved user interface and an analytics engine that will provide physicians with critical information regarding at-risk patients. An example of a new feature with the upgraded CURES 2.0 is that prescribers will be able to specify patients with whom they have pain management agreements to signal to other providers that additional prescribing of controlled substances to these patients could be potentially counter-productive or harmful. The new CURES 2.0 also provides alerts to physicians if a patient meets certain criteria, such as a patient who has obtained prescriptions from six or more prescribers or six or more pharmacies during the last six months. These alerts are viewable on the physicians’ dashboard when they sign on to the CURES 2.0 system.
CURES 2.0 is also impacted by the confidentiality and disclosure provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and of similar California laws.
Who has to Register?
The mandatory consultation requirement of SB-482 applies to any health care practitioner with both (1) a Drug Enforcement Administration Controlled Substance Registration Certificate and (2) a California licensure as any one of the following:
- Dentist
- Physician
- Naturopathic Doctor
- Optometrist
- Osteopathic
- Doctor
- Physician Assistant
- Podiatrist
- Registered Certified Nurse Midwife (Furnishing)
- Registered Nurse Practitioner (Furnishing)
Health and Safety Code, §§ 11150 and 11165.4(a)(1)(A)(i).
Certain other exemptions apply. The mandatory use requirement of SB-482 does not apply to Veterinarians or Pharmacists (Health and Safety Code, § 11165.4(b).)
California law (Health and Safety Code Section 11165.1) requires all California licensed prescribers authorized to prescribe scheduled drugs to register for access to CURES 2.0 by July 1, 2016 or upon issuance of a Drug Enforcement Administration Controlled Substance Registration Certificate, whichever occurs later.
California licensed pharmacists must register for access to CURES 2.0 by July 1, 2016, or upon issuance of a Board of Pharmacy Pharmacist License, whichever occurs later.
The Department of Justice is providing webinars on the CURES 2.0 system for prescribers and dispensers, which will show attendees how to access CURES patient activity reports, reset user passwords, and see new system features, such as Patient Safety Alerts, Compacts, and Peer Messaging. Go to https://cures.doj.ca.gov to view and register for the scheduled webinars. Or contact the CURES Help Desk at CURES@doj.ca.gov or (916) 210-3187.
For additional information regarding the CURES consultation requirement: See the CURES 2.0 Mandatory Use reference sheet and CURES Advisory Memo of April 2018 from the Department of Justice. See also the Medical Board’s links and videos.
At Simas and Associates, we have a long history of working with allied health professions in licensing and enforcement cases – including the cascade of collateral effects (federal programs, insurance, licensure in other states, privileges, etc.). If you are a licensed professional concerned about an investigation or accusation, or want additional information on obtaining or modifying a license, please contact us.
The CURES system will assist those who have a Corresponding Responsibility – see our related blog.