Dispenser Reporting of Noncontrolled Prescription Drugs
Overview
Maryland law (2022) requires pharmacists and health care practitioners authorized to dispense prescription drugs in the State, to submit noncontrolled prescription drug (non-CDS) information to the State’s Health Data Utility (HDU) operated by the State-Designated Health Information Exchange (CRISP). The law aims to promote health equity and treatment efficacy by expanding access to non-CDS dispense information for purposes of patient treatment, care coordination, public health, and quality improvement. COMAR 10.25.18, Health Information Exchanges: Privacy and Security of Protected Health Information, is the regulatory framework to support implementation of the law.
Implementation
Dispenser Data Submission Manual
As required by the regulations, a Noncontrolled Prescription Drugs Dispenser Data Submission Manual (dispenser manual) includes technical specifications for reporting non-CDS dispense information, including required data elements, formatting standards, and submission procedures and timelines. A multi-stakeholder approach guides iterative development of the dispenser manual.
Current Version:
Noncontrolled Prescription Drugs Dispenser Data Submission Manual V1.0 (June 2025)
The MHCC is required to publish the dispenser manual in the Maryland Register for a public comment period annually. Draft updates to the dispenser manual were identified in collaboration with CRISP and based on feedback received from reporting dispensers. The MHCC is soliciting public comments on proposed updates to the draft manual version 1.2 through May 7, 2026. Please submit any questions an comments to mhcc.nondcs@maryland.gov.
Proposed Updates:
DRAFT Noncontrolled Prescription Drugs Dispenser Data Submission Manual V1.2 (March 2026)
CRISP Onboarding
CRISP has partnered with Leap Orbit to securely collect and store dispense information using RxGov. Dispensers who do not already submit dispense data to the Maryland PDMP must register with RxGov here. For more information, click here or contact the CRISP Technical User Support team by phone at 1.877.952.7477 or email at support@crisphealth.org. Pharmacies should include “Pharmacy Onboarding for Non-CDS” in the subject line of their email..
Waiver Request
COMAR 10.25.18.13, Section F allows dispensers to request a time-limited waiver from reporting non-CDS dispense information under certain conditions. Pharmacies and prescribers who hold a dispensing permit from their respective Maryland licensing Board may request a waiver. The waiver request form can be found here.
A waiver request may be submitted on behalf of multiple pharmacies or dispensing prescribers. Respondents who plan to submit a request on behalf of pharmacies with multiple locations or multiple dispensing prescribers are required to complete a supplemental form here and email it to mhcc.noncds@maryland.gov.
Please direct any questions regarding the waiver request process to mhcc.noncds@maryland.gov.
Webinars
This MHCC webinar includes background information on the law and supporting regulations for non-CDS reporting. Key components of the Noncontrolled Prescription Drug Dispenser Data Submission Manual and dispenser waiver process are discussed..
- Blueprint for Dispenser Reporting of Non-CDS Dispenses in Maryland, July 23, 2025: Recording; Slides
This CRISP webinar includes technical information on the process for submitting non-CDS dispense information using RXGov. Processes that are similar or differ from existing reporting to the MD PDMP are discussed.
- Non-CDS Data Submission Webinar, July 29, 2005: Recording
Additional Resources
For more information about the value of non-CDS reporting and how dispensers can start reporting non-CDS data to CRISP, check out the following resources:
Contact Us
Questions about the regulatory requirements for non-CDS reporting can be directed to mhcc.noncds@maryland.gov