Non-CDS Medication Data

Reporting of Non-Controlled (Non-CDS) Medication Data

Overview

The Maryland Health Care Commission (MHCC) and CRISP have begun 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 were required to begin reporting non-CDS data starting September 1st, 2025.

Through the contract between CRISP and Leap Orbit, dispense data is securely collected and stored using RxGov. This is a web-based program that does not require additional hardware or software. Dispense data available for a given patient will be visible to CRISP clinical users under the Medication Management tab of InContext and Clinical Information, within the new Dispensed Medications subtab.

For Dispensers

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 – (Allows full clinical access; see sample here)
Connection Agreement (See sample here)

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.org with 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 and Reporting Processes

Click here to access the new submission website.

Current Submitters of Controlled Data	New Submitters of Medication Data
Registration: To begin submitting non-CDS medication data, dispensers with existing accounts must reset their password through the new submission website. After a password reset, dispensers may log in through the new website as normal.	Registration: To begin submitting non-CDS medication data, dispensers without existing accounts must create an account with RxGov through the new submission website. Once an account is created, dispensers may log in and begin submitting data.
Reporting Process: Dispensers who already report controlled medication data can submit one file with both CDS and non-CDS dispense information. The database will identify and separate the medications into the appropriate database.	Reporting Process: Dispensers who have not previously submitted dispense information can submit their file containing dispense information through RxGov once registered.

Current Submitters of Controlled Data

New Submitters of Medication Data

Registration:
To begin submitting non-CDS medication data, dispensers with existing accounts must reset their password through the new submission website. After a password reset, dispensers may log in through the new website as normal.

Registration:
To begin submitting non-CDS medication data, dispensers without existing accounts must create an account with RxGov through the new submission website. Once an account is created, dispensers may log in and begin submitting data.

Reporting Process:
Dispensers who already report controlled medication data can submit one file with both CDS and non-CDS dispense information. The database will identify and separate the medications into the appropriate database.

Reporting Process:
Dispensers who have not previously submitted dispense information can submit their file containing dispense information through RxGov once registered.

For Clinicians

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 and treating. CRISP will display noncontrolled medication data as part of the standard clinical data. This ensures medication information is easily accessible next to other medical data, providing a full view of a patient’s treatment.

How Do I Get Clinical Access?

All organizations seeking clinical access must sign a Standard Participation Agreement with CRISP before getting started.

If you have already signed a Participation Agreement and still need clinical access, please contact CRISP at support@crisphealth.org and we will work with you to ensure that individuals at your organizations receive appropriate access.

More detailed information on getting connected with us is available on our onboarding webpage.

Viewing Data

Dispensed medication data will be available through the Clinical Information Service and the InContext Application. To view dispensed medication information available for a given patient:

Navigate to the Medication Management tab.
Click the Dispensed Medications subtab.

Reported Medications vs Dispensed Medications

When viewing medication data, there are two different tabs data could fall under: Reporting and Dispensed Medications.

Medication under the Reported Medications tab comes from CCDs that we are able to parse.
The Dispensed Medications tab includes the data reported daily through RxGov by dispensers. This data includes information required in state regulations. Reporting of dispensed medications was required in Maryland starting September 1st, 2025.