In most states today, dentists have some form of due diligence or best practice requirements regarding their patients and a patient’s potential abuse of narcotics. As an example, in Ohio, a dentist must obtain and review an Ohio Automated Rx Reporting System (OARRS) report to help determine if it is appropriate to prescribe certain types of medications, such as an opioid analgesic, benzodiazepine, or other reported drugs, when the patient is “traveling an extended distance or from out of state to the dentist’s office.” [Ohio Admin. Code Rule 4715-6-01(C)(3)(j).]

But, does a dentist have additional obligations when the patient is traveling from out of state?

We recently addressed this question for one of our dental clients. Specifically in Ohio, if a dentist practices in a county that adjoins another state, that dentist must request a report of any information available in OARRS related to prescriptions issued or drugs furnished to the patient in the state adjoining that county. [Ohio Admin. Code Rule 4715-6-01(F)(3).]

Ohio actually participates in electronic data sharing with other states through OARRS. This program is referred to as Prescription Monitoring Program InterConnect (“PMP InterConnect”). In fact, all five states that border Ohio share information with Ohio, and 33 other states do as well. [Interstate PDMP Access and Data Sharing Alignment, Prescription Drug Monitoring Program Training and Technical Assistance Center (January 2021), https://www.pdmpassist.org/pdf/resources/Interstate_PDMP_Access_and_Data_Sharing_Alignment_20210125.pdf.]

We recently contacted the OARRS Support team about this and learned that this information is available through OARRS by using the PMP InterConnect Search box, where specific states can be added when a prescriber uses the search function. This is super-useful information.

Nardone Comment: In providing this guidance, we asked ourselves how many dentists are actually aware of this search function through OARRS and are using the data-sharing program. We think it is likely that many of the dentists we work with, who are some of the best providers out there, are using it. But, we guess that there are some who may not have knowledge of the ability to search multiple states all at the same time.

We would encourage each of our clients, as well as the dental community in general, to read up on the requirements for your specific state. As we continue to battle the very common and very heart-wrenching and life-altering diseases of substance and alcohol disorders and dependencies, we can all do our part by reading up on them and taking certain due diligence/best practice steps to minimize access.

For some additional related blog posts, see below.

State of Ohio’s Board of Pharmacy Upgrade to Ohio Automated Rx Reporting System (OARRS)

Patients with Substance Abuse Problems

Vince Nardone is a partner with Benesch, with a focus in Benesch’s healthcare practice, and specifically a leader in the dental industry. He is a thought leader and regular speaker in the dental industry. He may be reached at (614) 223-9326 or vnardone@beneschlaw.com.

Angelina Campin is an associate with Benesch, and focuses her practice on healthcare matters in both transactional and regulatory areas. She may be reached at (312) 506-3424 or acampin@beneschlaw.com.