Non-CDS Medication Data

Overview

The Maryland Health Care Commission (MHCC) and CRISP are beginning collection of non-controlled substances (“non-CDS”) in accordance with Maryland House Bill 1127 Public Health – State Designated Exchange – Health Data. CRISP, in partnership with Leap Orbit, has built an infrastructure to receive, process, store and deliver non-CDS data. Dispensers will be required to begin reporting non-CDS data starting September 1st, 2025. 

Through the contract between CRISP and Leap Orbit, dispense data will be securely collected and stored using RxGov. This is a web-based program that does not require additional hardware or software.

Clinical Benefits

Through this new infrastructure, CRISP clinical users will be able to review data on all medications a patient has received – not just controlled substances. This will help providers stay properly informed about their patient when prescribing, as well as monitor whether a prescription has been filled by the patient. CRISP will display noncontrolled medication data as part of the standard clinical data, keeping all the information centralized in one place.

Agreement Requirements

As the state designated HIE/HDU, CRISP is responsible for collecting non-controlled medication data

Per CRISP policy, submitters are required to sign one of two agreements:

• Standard Participation Agreement
• Connection Agreement

Note: If submitters have sufficient reason why they are not able to submit right now, they submit a waiver for the year through MHCC. If a waiver is accepted, no agreement is required.

Note: If submitters have sufficient reason why they are not able to submit right now, they can submit a waiver for the year through MHCC. More information available on the MHCC website. If a waiver is accepted, no agreement is required

If you want to sign a Participation Agreement (PA) or Connection Agreement (CA):

• Please email CRISP Support at support@crisphealth.orgwith the subject line: Pharmacy Onboarding for Non-CDS – [Agreement Name of your choosing]
• Once you’ve emailed us, we will send the appropriate form and instructions for signature.
• We can send samples for review, but please reach out to us directly to complete the agreement

Registration Requirements

Dispensers that already submit controlled substance data to the Maryland PDMP will need to create a new account here in order to log in. However, once that account is created, they can simply use their existing information to submit noncontrolled dispense data.

Dispensers that do not already submit dispense data to the Maryland PDMP will need to register with RxGov before they can begin submitting dispense data. 

To register with RxGov, click here.

Reporting Processes

To minimize burden and duplication of data, processes for non-CDS reporting are similar to existing technical requirements for reporting to the Maryland PDMP.

• Dispensers who already report CDS data to the PDMP can submit one file with both CDS and non-CDS dispense information.
  • The database will identify and separate CDS and non-CDS medications.
  • Each has their own set of validation rules to determine errors and warnings.
• Dispensers who have not previously submitted to the PDMP can submit their file through RxGov once registered.
  • Please note that these dispensers will not need to begin submitting data with RxGov until September 1st.

For information on submission requirements, please refer to the Maryland Health Care Commission (MHCC) manual.