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 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).
Preliminary planning for non-CDS reporting began with the Noncontrolled Prescription Drugs Workgroup (October 2022 to February 2023). Stakeholders included representatives from dispensing organizations (chain and independent pharmacies), technology vendors, (including CRISP), and the Nebraska and Maryland PDMPs. Among other things, the workgroup considered technical specifications for non-CDS reporting, which informed the development of a dispenser data submission manual. Workgroup discussions ensured processes to report non-CDS aligned closely, to the extent possible, with the Maryland PDMP, as required by the law.
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. The regulations require dispensers to begin reporting non-CDS dispense information to CRISP (via RxGov) by September 1, 2025.
Dispenser Data Submission Manual
As required by the regulations, MHCC drafted the Noncontrolled Prescription Drugs Dispenser Data Submission Manual (dispenser manual). A multi-stakeholder approach guided iterative development of the draft dispenser manual, which offers technical guidance to dispensers and their technology vendors on how to submit non-CDS dispense information to RxGov.
DRAFT – Noncontrolled Prescription Drugs Dispenser Data Submission Manual (April 2025)
COMAR 10.25.18 requires MHCC to consider public comments on the dispenser manual annually. A link to the draft dispenser manual was posted in the May 2, 2025 edition of the Maryland Register; public comments will be accepted through May 22, 2025. Please submit comments to mhcc.noncds@maryland.gov.
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 Customer Care 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.
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