State Delegate(s) Notes

July 27, 2022
To: Rachael Lu
From: Samantha Triplett, PharmD; Samuel Hwang, PharmD
CC: Austin Mondloch, PharmD
Re: List of States Allowing Physician Delegation of PDMP Access
______________________________________________________________________________________________________________________
In response to your request regarding a physician's ability to delegate prescription drug monitoring program (PDMP) check responsibilities, the
following information is provided.
Response:
After review, state laws typically do not express the qualifications required for an individual to be defined as a delegate/designate of the
practitioner. In general, all states allow for practitioners/prescribers to delegate/designate another individual to access the states prescription
drug monitoring program (PDMP) databases on their behalf. The description of who can be appointed a delegate/designate was primarily found
in the respective states PDMP frequently asked questions section. The information collected for each state can be found in Table 1 below.
Table 1. PDMP Practitioner Delegation per State

State Delegate(s) Notes
 Nurse practitioner/clinical nurse specialist, physician  Must be authorized to prescribe, administer, or dispense pursuant to a
Alabama1-3 assistant, or midwife with prescriptive authority. Qualified Alabama Controlled Substances Registration Certificate.
 Prescriber delegate – unlicensed.  PDMP access is limited to information regarding current or prospective
patients of the delegate.
 Allowed 2 delegates.
 Agent or employee authorized by the practitioner to  Agent or employee must be licensed under AS 08 (athletic trainers,
Alaska3-6 access the database on the practitioner’s behalf. audiologists, speech-language pathologists, chiropractors, dentists,
dental hygienists, dietitians, nutritionists, certified direct-entry
midwives, physicians, nurses, optometrists, pharmacists,
physical/occupational therapists, professional counselors, psychologist,
social workers, veterinarians).
1
 Information must relate to a current patient of the practitioner and the
practitioner is prescribing or considering prescribing a controlled
substance.
 Delegate qualifications/requirements are not specified.
 Licensed pharmacy technicians, pharmacy interns,  No mention of a limit of delegates allowed.
Arizona7,8 nurses, registered dental hygienists.
 Other staff trained in HIPAA laws, such as front office,
medical assistants or dental assistants.
 Licensed or unlicensed agent or employee of  Delegate qualifications/requirements are not specified.
Arkansas9,10 prescriber or dispenser.  No mention of a limit of delegates allowed.
 Prescriber, out-of-state prescriber, non-DEA  Delegates must be 18 years of age or older.
California11-13 practitioner, pharmacist, out-of-state pharmacist, or  Delegate sponsor initiates the creation of the delegate account.
an authorized health care provider under the same  Allowed 50 delegates.
covered entity (health plan).
 Employed by or under contract with the same Delegate qualifications/requirements are not specified.
Colorado3,14,15 professional practice as the practitioner. Allowed 3 designees.
 Authorized agent, licensed or unlicensed, by the Delegates must register for their own CPMRS account.
Connecticut3,16 practitioner. Delegate qualifications/requirements are not specified.
No mention of a limit of delegates allowed.
 Authorized by a Delaware-licensed practitioner. Authorized access to PMP on practitioner’s behalf.
Delaware17 Delegate qualifications/requirements are not specified.
No mention of a limit of delegates allowed.
 Designee of the prescriber or dispenser. Delegates must complete information security and privacy training prior
Flordia3,18,19  “Designee” – a person, preferably a licensed or to registration.
certified health care professional authorized to act as  Designees/delegates must register with the E-FORCSE program.
an agent of a prescriber for the purposes of  Delegate qualifications/requirements are not specified.
requesting or receiving information from the PDMP,  No mention of a limit of delegates allowed.
E-FORCSE.
 Employee of the prescriber or the health care facility  Licensed under chapter 11, 30, 34, or 35 of Title 43 (licensed dentist,
Georgia3,20-27 where the prescriber is practicing and professionally dental hygienist, optometrist, physician, physician’s assistant, and
licensed (dental hygienist, dentist, optometrist, podiatrist).
physicians, acupuncturist, physician assistant,
2
oncologist, pulmonologist, perfusionist, orthopedic,  Registered under Title 26 (licensed pharmacist, pharmacist intern, or
podiatrist, and nurses) or registered pharmacists in registered pharmacy technician).
Georgia.  Delegates and supervising physicians must maintain annual registration
 Or anyone who passes the online “Georgia with the PDMP, issued by the State Board of Pharmacy.
Prescription Drug Monitoring Database:  Allowed 2 delegates per shift, if the authorized individuals are employed
Understanding Your Responsibilities” training course by the emergency department in which the prescriber practices and are
with a score of at least 70, receive instruction on the approved by the hospital medical director.
prescriber or dispenser’s PDMP security policy, and
sign a DPH ‘responsibility statement’ that must be
placed in the delegate’s personal file.
 Individuals authorized by the prescriber.  If a staff member from the practitioner’s office (i.e. office manager)
Hawaii3,28,29 signs up as a delegate, there is a dual approval process, the supervisor
and the PDMP administrator must approve the delegate.
 Delegates must be under the practitioner’s  Delegates must provide supervisors information to be registered for an
Idaho3,30,31 supervision. account in the PDMP.
 Information must relate to a current patient of the practitioner and the
practitioner is prescribing or considering prescribing controlled
substances for that patient.
 Licensed healthcare professionals are authorized  The prescriber and dispenser shall register the designees and must
Illinois3,32,33 designees for a prescriber or dispenser for office or agree to the terms and conditions for designees.
pharmacy practice sites (registered nurse, licensed  Designees must have their own PDMP account that is linked to the
practical nurse, pharmacy technician, student supervising prescriber or dispenser.
pharmacist, or certified medical assistant).  Prescribers can share designees.
 Allowed 3 designees.
 A practitioner’s agent, an individual authorized by the  Delegates must be approved and supervised by a registered prescriber.
Indiana3,34-36 practitioner and acts on behalf of the practitioner.  Delegate qualifications/requirements are not specified.
 No mention of a limit of delegates allowed.
3
 Licensed, registered, or certified health care  Non-prescribing employees in the same practice as the practitioner.
Iowa3,37-39 professional practicing under the supervision of the  The number of agents/delegates is not limited, practitioners can
practitioner. authorize as many delegates as they want, as long as those delegates
are actively working with the practitioner.
 Registered nurse, licensed practical nurse, registered  Delegates must be licensed by a state regulatory board, medical
Kansas40,41 respiratory therapist, registered dental hygienist, assistants and office managers are not allowed.
certified pharmacy technical, emergency medical  Delegates must be approved by their supervisors to access PDMP data.
technician, paramedic, or pharmacy intern.  Allowed 10 delegates.
 Employee of the practitioner’s practice and under the  The “master account holder” (supervising practitioner) must register
Kentucky3,42-44 specific direction of the practitioner (nurses, medical their delegates.
assistants, pharmacy technicians, and other office  There is no limit to the number of delegates a practitioner can have.
staff).
 Authorized PMP user by the practitioner.  The supervising practitioner must be registered and approved in the
Louisiana45-47 PMP before the delegate can register their account.
 Any staff member duly authorized by a prescriber and  Patients must be under the prescriber’s, hospital’s emergency
Maine3,48,49 the Maine Department of Health and Human Services department, or hospital’s inpatient care.
or Office of Substance Abuse and Mental Health  No mention of a limit of delegates allowed.
Services.
 Any staff member of a licensed hospital authorized by
the chief medical officer of the hospital.
 Staff members of a group practice, designated by the
group practice leader, authorized as information
relates to a patient receiving care from the group
practice.
 Licensed or unlicensed.
 Non-prescribing licensed health practitioner (nurse,  A practitioner can have multiple delegates.
Maryland50-52 professional counselor, therapist, psychologist, social
worker, certified pharmacy technician, pharmacist
resident, registered nurse).
4
 A staff member, regardless of licensure that is
employed or under contract with the same practice
site as the supervising prescriber.
 Non-prescribers authorized by enrolled prescribers  Supervising prescriber must be enrolled in MassPAT.

Massachusetts53,54 (such as a registered nurse or medical assistant  No mention of a limit of delegates allowed.
working in the same office as the prescriber)
 Staff member of the prescriber (e.g. registered nurse,  Delegates must be registered in MAPS as a prescriber delegate and
Michigan55,56 office administrator). select their supervising prescriber before requesting data in MAPS.
 A prescriber can have 10 active delegates.
 A delegate can run MAPS reports on behalf of 30 active licensed
prescribers.
 An agent or employee of the prescriber.  The supervising practitioner must audit the delegate’s use of the PDMP
Minnesota57,58 at least quarterly.
 A supervising practitioner can have multiple delegates and a delegate
can have multiple supervisors.
 Physicians, physician assistants, and dentists may  A delegate must have had recent contact with the patient, actively
Mississippi59,60 have anyone as a delegate. providing medical care, or dispensing medications to run a report in
 A nurse practitioner can only have a registered nurse MSPMP.
or licensed practical nurse as a delegate.  The practitioner can have as many delegates as comfortable
 A pharmacist can only have a registered pharmacy supervising, and a delegate can have multiple supervisors.
technician as a delegate.
 Nurse practitioner/clinical nurse specialists, midwife  No mention of a limit of delegates allowed.
Missouri61,62 with prescriptive authority, physician assistant,
medical resident, medical assistant, medical intern,
dental hygienist, and nurse.
 Authorized agents or delegates of the supervising  The supervising provider is responsible for monitoring the delegate’s
Montana3,63 provider use of the MPDR.
5
 Anyone licensed or registered health care  Delegates must be under the supervision of the practitioner.
Nebraska64,65 professional credentialed under the Uniform  Uniform Credentialing Act includes a license, certificate, or registration
Credentialing Act designated to act as an agent of the provided by the Division of Public Health and Department of Health and
prescriber. Human Services.
 The Division of Public Health and Department of Health and Human
Services will provide certification of the credential.
 Assigned by the practitioner or dispenser  Delegates must register their own PMP account.
Nevada3,66  Delegate qualifications/requirements are not specified.
 Prescribers and dispensers can allow access to the  Access is granted for the purpose of providing information on a specific
New Hampshire3,67 NHPDMP to their registered delegate. patient for which a prescription was written or an appointment was
scheduled or conducted.
 Registered prescribers may delegate authority to  Delegates are required to be licensed in the State of New Jersey.
New Jersey3,68 access NJPMP to certain other healthcare  Delegates must register and link to a prescriber in NJPMP before
professionals (registered nurse, licensed practical accessing data.
nurse, advanced practice nurse without prescriptive  Registered dental hygienists must complete the requirements
authority, physician assistant without prescriptive established in N.J.A.C. 13:45A-35.8.
authority, athletic trainer employed in a clinical  CMAs must meet all requirements, certify that they have completed the
practice setting, dental hygienist, registered dental necessary training, and provide a copy of the certificate of completion
assistants). from a State-approved program.
 Medical or dental residents can be delegates if  No mention of a limit of delegates allowed.
authorized by a faculty member from a medical or
dental teaching facility.
 Certified medical assistants (CMA) and medical
scribes may register as an unlicensed delegate.
 Licensed or unlicensed authorized individuals or  Delegates must register and link PDMP accounts to the supervising
New Mexico3,69 agents supervised by the practitioner prescriber.
 Practitioners are allowed 4 delegates.
 Delegates cannot have more than 7 supervising physicians.
6
 Designated staff by the practitioner or pharmacist.  Unlicensed delegates will need to work with the HCS coordinator from
New York3,70  Pharmacy delegates are limited to other pharmacists their facility, or prescribing practitioner, to establish their own HCS
and pharmacy interns. account.
 Delegate qualifications/requirements for the practitioner delegates are
not specified.
 Authorized by the supervising practitioner for the  Delegates must register on the CSRS website.
North Carolina3,71 purpose of providing medical or pharmaceutical care  The Department of Health and Human Services must approve the
for their patients. delegation of authority to check the PMP.
 Registered nurse, licensed practical nurse, or  Delegates must work for the practitioner or by the same employer of
North Dakota3,72 unlicensed individual the practitioner.
 Authorized representative registered with the Ohio  The practitioner can have as many delegates as are comfortable
Ohio3,73,74 board of pharmacy to obtain an OARRS report on supervising.
behalf of the physician.  A delegate can have multiple supervising practitioners.
 Authorized by the supervising practitioner.  Delegates must be under the supervision or employment of the
Oklahoma3,75,76 authorizing medical professional and must have their own account
registration with the Oklahoma PMP.
 A staff member authorized by the practitioner to  Prescribers are not limited to the number of delegates they can have.
Oregon3,77 access the PDMP system on their behalf.  Delegate qualifications/requirements are not specified.
 Authorized employee or supervised by the prescriber.  Delegates do not have to be licensed healthcare professionals.
Pennsylvania3,78,79  No mention of a limit of delegates allowed.
 Authorized designee of the prescriber.  Designees must be employed by the same professional practice as the
Rhode Island3,80,81 prescriber and be supervised by the prescriber.
7
 An individual directly supervised and approved by the  Practitioners must have direct supervision of any delegates.
South Carolina3,82,83 authorizing practitioner  Practitioners must re-confirm delegate accounts at least once every 180
days.
 Authorized delegate by the practitioner  Delegates must register in the PDMP system and be approved by the
South Dakota3,84 supervising practitioner.
 Any person designated and authorized by a  Delegates must register as a PDMP user and provide information to link
Tennessee3,85,86 healthcare practitioner to check the controlled their account to their supervising practitioners account.
substance database.  Delegate qualifications/requirements are not specified.
 No limit of healthcare practitioner delegates.
 Nurses, medical residents, administrative staff, etc.  A practitioner can have as many delegates as comfortable supervising.
Texas3,87,88  A delegate can have multiple supervising practitioners.
 Authorized individual employed by the practitioner.  Delegates must fill out a CSD proxy application form and be approved by
Utah3,89 the Utah Department of Commerce Division of Occupational and
Professional Licensing.
 Delegates must be properly trained to access the CSD.
 A practitioner is allowed an unlimited number of delegates.
 Individuals employed by the prescriber or in the  Delegates are authorized to access the VPMS related to the clinical care
Vermont3,90,91 office of the chief medical examiner. of bona fide current patients of the authorizing health care prescriber.
 Individuals employed or engaged at the same facility  No mention of a limit of delegates allowed.
Virginia3,92,93 and under direct supervision of the prescriber and
are licensed, registered, or certified by a health
regulatory board under the Department of health
professions or in another jurisdiction or have routine
access to confidential patient data and have signed a
patient confidentiality agreement.
8
 A licensed healthcare profession that works for the  No mention of a limit of delegates allowed.
Washington94,95 authorizing prescriber (registered nurse, medical
assistant).
 A licensed healthcare professional (nurse,  No mention of a limit of delegates allowed.
West Virginia3,96 professional counselor, therapist, psychologist, social
worker, certified pharmacy technician, pharmacy
resident, etc.) that is employed by or under contract
with the same professional practice as the registered
prescriber.
 An individual supervised by the healthcare  The supervising prescriber must initiate the delegates account,
Wisconsin3,97,98 professional. delegates must be assigned by the master account holder.
 Authorized agents of the practitioner.  Delegates must register with the PDMP to access the information for
Wyoming3,99,100 the provider.
 Delegates must be employed by the practitioner’s location.
 A practitioner is allowed 2 delegates.
 A delegate registered with one practitioner may perform searches for
others.
Thank you for contacting the Christy Houston Foundation Drug Information Center at the Belmont University College of Pharmacy. Please do not
hesitate to contact the Drug Information Center at 615-460-8382 or druginfo@belmont.edu with any additional questions.
References:
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9
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10
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Questions.pdf?rev=3f94e736057b4bba87aa5a05f6abdbe9&hash=6DD3E332066E691B421812AEE146C89F
56. MAPS users. Michigan Licensing and Regulatory Affairs. Accessed July 26, 2022. https://www.michigan.gov/lara/bureau-list/bpl/health/maps/users
12
57. 2021 Minnesota statutes 152.126 prescription monitoring program. Minnesota Legislature Office of the Revisor of Statutes. Updated 2021. Accessed
July 26, 2022. https://www.revisor.mn.gov/statutes/cite/152.126
58. Access FAQs. Minnesota Board of Pharmacy Prescription Monitoring Program. Updated March 2022. Accessed July 26, 2022.
https://www.pmp.pharmacy.state.mn.us/access-faqs
59. Laws & regulation MS PMP guidelines. Mississippi Prescription Monitoring Program. Accessed July 26, 2022. https://pmp.mbp.ms.gov/wp-
content/uploads/2022/03/2022-PMP-GUIDELINES.pdf
60. Frequently asked questions. Mississippi Prescription Monitoring Program. Accessed July 26, 2022. https://pmp.mbp.ms.gov/frequently-asked-
questions/
61. Registration guide. St. Louis County Prescription Drug Monitoring Program. Accessed July 26, 2022. https://pdmp-stlcogis.hub.arcgis.com/
62. PDMP healthcare professional delegate users. St. Louis County Prescription Drug Monitoring Program. Updated May 8, 2017. Accessed July 26, 2022.
https://stlcogis.maps.arcgis.com/sharing/rest/content/items/1155dd335143444893518d4d23a5cf8f/data
63. Delegate access. Montana Prescription Drug Registry (MPDR). Accessed July 25, 2022. https://boards.bsd.dli.mt.gov/pharmacy/mpdr/
64. Legislative bill 223. Nebraska Legislature. Updated 2017. Accessed July 25, 2022. https://nebraskalegislature.gov/FloorDocs/105/PDF/Final/LB223.pdf
65. Statutes relating to uniform credentialing act. Nebraska Department of Health and Human Services. Updated 2021. Accessed July 25, 2022.
https://dhhs.ne.gov/licensure/Documents/UniformCredentialingAct.pdf
66. Nevada prescription monitoring program (PMP). Delegate Instructions. Accessed July 25, 2022.
https://bop.nv.gov/uploadedFiles/bopnvgov/content/Links/PMP%20Flier%20-%20Delegate%20Instructions.pdf
67. New Hampshire liability statement for prescriber/pharmacist/sub-account user access. New Hampshire PDMP. Accessed July 25, 2022.
https://newhampshirepdmp.com/practitionerpharmacist/liability-statement.html
68. NJ prescription monitoring program - frequently asked questions. New Jersey Consumer Affairs. Updated February 12, 2020. Accessed July 25, 2022.
https://www.njconsumeraffairs.gov/pmp/Pages/FAQ.aspx
69. Delegates and supervisors. New Mexico Board of Pharmacy Prescription Monitoring Program. Accessed July 25, 2022.
https://www.nmpmp.org/delegates-and-supervisors-2/
70. Frequently asked questions for the NYS PMP registry. New York State Department of Health. Updated Jun, 2017. Accessed July 25, 2022.
https://www.health.ny.gov/professionals/narcotic/prescription_monitoring/docs/pmp_registry_faq.pdf
71. Chapter 90 article 5E. North Carolina General Assembly. Accessed July 26, 2022.
https://www.ncleg.net/enactedlegislation/statutes/html/byarticle/chapter_90/article_5e.html
72. Prescription drug monitoring program - frequently asked questions. North Dakota Board of Pharmacy. Accessed July 25, 2022.
https://www.nodakpharmacy.com/PDMP-faq.asp
73. Frequently asked questions. Ohio Automated Rx Reporting System. Accessed July 26, 2022. https://www.ohiopmp.gov/FAQ.aspx
74. 4731-11-11 Standards and procedures for review of “Ohio Automated Rx Reporting System” (OARRS). Ohio Laws & Administrative Rules Legislative
Service Commission. Updated September 30, 2021. Accessed July 26, 2022. https://codes.ohio.gov/ohio-administrative-code/rule-4731-11-11
13
75. Oklahoma prescription monitoring program terms and conditions. Bureau of Narcotics & Dangerous Drugs Control. Updated July 27, 2022.
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76. Prescription monitoring program enhancements. Oklahoma PMP. Accessed July 26, 2022.
https://www.deadiversion.usdoj.gov/mtgs/pract_awareness/conf_2019/may_2019/mcguire.pd
77. Public health division - Chapter 333. Oregon Secretary of State. Updated January 10, 2017. Accessed July 25, 2022.
https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=123
78. Prescriber and pharmacist delegate assignment policy. Pennsylvania Department of Health Prescription Drug Monitoring Program. Accessed July 25,
2022. https://www.health.pa.gov/topics/Documents/Programs/PDMP/PAPDMP-Delegate_Policies.pdf
79. Tutorials and policies. Pennsylvania Department of Health. Accessed July 25, 2022.
https://www.health.pa.gov/topics/programs/PDMP/Pages/Tutorial.aspx
80. R.I. Gen. Laws § 21-28-3.32 (3). State of Rhode Island General Assembly. Updated June 25, 2021. Accessed July 27, 2022.
http://webserver.rilin.state.ri.us/Statutes/TITLE21/21-28/21-28-3.32.HTM
81. Title 216-RICR-20-20-3. Department of Health. Updated May 15, 2018. Accessed July 26, 2022. https://risos-apa-production-
public.s3.amazonaws.com/DOH/REG_9468_20180806190645.pdf
82. Article 15. prescription monitoring program. South Carolina Department of Health and Environmental Control. Updated June 14, 2006. Accessed July
25, 2022. https://scdhec.gov/sites/default/files/media/document/PMPLaw_0.pdf
83. PMP delegate policy. South Carolina Department of Health and Environmental Control. Accessed July 25, 2022. https://scdhec.gov/health-
regulation/drug-control-register-verify/prescription-monitoring/pmp-delegate-policy
84. Frequently asked questions. State of South Dakota Prescription Drug Monitoring Program. Accessed July 27, 2022.
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85. Controlled substance monitoring database (CSMD) and Prescription Safety Act. Tennessee Department of Health. Updated May 20, 2022. Accessed
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86. Rule chapter 1140-11 controlled substance monitoring database. Publications Tennessee Secretary of State. Updated March 2020. Accessed July 27,
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87. Frequently asked questions. Texas Prescription Monitoring Program. Accessed July 26, 2022. https://txpmp.org/faq#r-delegates
88. Texas. Prescription Drug Monitoring Program Training and Technical Assistance Center. Updated July 13, 2022. Accessed July 26, 2022.
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89. Controlled substance database proxy information. Utah Department of Commerce Division of Occupational and Professional Licensing. Accessed July
26, 2022. https://dopl.utah.gov/csd/index.html
90. Chapter 84A: Vermont prescription monitoring system. Vermont General Assembly. Updated October 1, 2013. Accessed July 26, 2022.
https://legislature.vermont.gov/statutes/fullchapter/18/084A
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91. Chapter 8 alcohol and drug abuse subchapter 7. Vermont Prescription Monitoring System Rule. Updated July 1, 2017. Accessed July 26, 2022.
https://www.healthvermont.gov/sites/default/files/documents/pdf/REG_vpms-20170701.pdf
92. Delegates prescription monitoring program - frequently asked questions. Virginia Department of Health Professionals. Accessed July 26, 2022.
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93. § 54.1-2523.2. Virginia Law. Updated July 2022. Accessed July 26, 2022. https://law.lis.virginia.gov/vacode/title54.1/chapter25.2/section54.1-2523.2/
94. Frequently asked questions. Washington State Department of Health. Accessed July 26, 2022. https://doh.wa.gov/public-health-healthcare-
providers/healthcare-professions-and-facilities/prescription-monitoring-program-pmp/frequently-asked-questions
95. FAQ for clinicians. Washington Prescription Monitoring Program. Accessed July 27, 2022. https://www.wapmp.org/wapmpfiles/ClinicianFAQ.pdf
96. Chapter 60A uniform controlled substances act. West Virginia Legislature. Accessed July 26, 2022.
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97. Chapter CSB 4 prescription drug monitoring program. Wisconsin State Legislature. Updated December 2017. Accessed July 26, 2022.
https://docs.legis.wisconsin.gov/code/admin_code/csb/4
98. Healthcare professionals FAQ. Wisconsin ePDMP. Updated January 17, 2017. Accessed July 27, 2022. https://pdmp.wi.gov/training-materials
99. Chapter 8: prescription drug monitoring program. Wyoming Pharmacy Laws. Updated December 11, 2018. Accessed July 26, 2022.
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100. PDMP updated Wyoming state board of pharmacy. State of Wyoming 66 th Legislature. Updated July, 2019. Accessed July 27, 2022.
https://wyoleg.gov/InterimCommittee/2019/S1-20190730PMPUpdate.pdf
15

State Delegate(s) Notes

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July 27, 2022

Table 1. PDMP Practitioner Delegation per State

 Non-prescribers authorized by enrolled prescribers  Supervising prescriber must be enrolled in MassPAT.

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