Noncontrolled Prescription Drugs (Non-CDS)
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 comprehensive medication histories in the interest 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 that supports implementation of the law.
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 to CRISP, including required data elements, formatting standards, and submission procedures and timelines. A multi-stakeholder approach guides iterative development of the dispenser manual; updates are considered at least annually.
Noncontrolled Prescription Drugs Dispenser Data Submission Manual V1.0 (June 2025)
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.
For more information, visit CRISP Non-CDS Medication Data, or contact the CRISP Technical User Support team:
- Phone: +1 (877) 952-7477
- Email: support@crisphealth.org
- Pharmacies should include “Pharmacy Onboarding for Non-CDS” in the subject line of their email.
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. Download the waiver request form.
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 must complete a supplemental form and email it to mhcc.noncds@maryland.gov.
For questions regarding the waiver request process, please email mhcc.noncds@maryland.gov.
Webinars
This MHCC webinar includes background information on the law and supporting regulations for non-CDS reporting. It also covers the Noncontrolled Prescription Drug Dispenser Data Submission Manual and dispenser waiver processes.
Additional Resources
For more information about the value of non-CDS reporting and how dispensers can start reporting non-CDS data to CRISP, see the following resources:
Contact Us
For questions about the regulatory requirements for non-CDS reporting, please email mhcc.noncds@maryland.gov.