Dispenser Reporting of Noncontrolled Prescription Drugs
Overview
Maryland law (2022) requires licensed dispensers, including pharmacists and health care practitioners authorized to dispense prescription drugs in the State, to electronically submit certain 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 comprehensive medication histories. CRISP must make non-CDS dispense information available for purposes of patient treatment, care coordination, public health, and quality improvement. Information on non-CDS dispenses will supplement dispense information on controlled dangerous substances made available by the Maryland Prescription Drug Monitoring Program (PDMP).
Implementation
COMAR 10.25.18, Health Information Exchanges: Privacy and Security of Protected Health Information, is the regulatory framework to support implementation of the law. Regulation.13 requires dispensers to begin reporting non-CDS dispense information to CRISP by September 1, 2025.
Dispenser Data Submission Manual
As required by the regulations, MHCC developed the Noncontrolled Prescription Drugs Dispenser Data Submission Manual (dispenser manual). A multi-stakeholder approach guided iterative development of the dispenser manual. Preliminary planning for non-CDS reporting began with the Noncontrolled Prescription Drugs Workgroup (October 2022 to February 2023). Among other things, the workgroup considered technical specifications for non-CDS reporting, which informed the development of the dispenser manual. Workgroup discussions ensured processes to report non-CDS aligned closely, to the extent possible, with the Maryland PDMP, as required by law.
The dispenser manual offers technical guidance to dispensers and their technology vendors on how to submit non-CDS dispense information to CRISP via RxGov.
Noncontrolled Prescription Drugs Dispenser Data Submission Manual (June 2025)
Questions or comments about the dispenser manual can be sent to mhcc.noncds@maryland.gov. Note, the regulations require MHCC to approve the dispenser manual annually after consideration of public comments. A link to the draft dispenser was posted in the May 2, 2025 edition of the Maryland Register; no public comments were received.
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 and 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.
FAQs
For more information about the value of non-CDS reporting and how dispensers can start reporting non-CDS data to CRISP, click here.
Contact Us
Questions about the regulatory requirements for non-CDS reporting can be directed to mhcc.noncds@maryland.gov