Starting October 2, 2018, health care practitioners authorized to prescribe, order, administer, or furnish a controlled substance must query, or consult, the Controlled Substance Utilization Review and Evaluation System (CURES) database and run a Patient Activity Report (PAR) on each patient the first time the patient is prescribed, ordered, or administered a Schedule II-IV controlled substance. First time is defined as the initial occurrence in which a health care practitioner intends to prescribe, order, administer, or furnish a controlled substance to a patient and has not previously prescribed a controlled substance to the patient. (Health and Safety Code (HSC), § 11165.4(a)(1)(B).)
The CURES consult and the PAR must be completed in the 24-hour period, or the previous business day, before prescribing, ordering, administering, or furnishing a controlled substance, unless an exception applies.
Thereafter, practitioners must consult CURES before subsequently prescribing a controlled substance, if the consult was previously exempt, and at least once every four months, if the controlled substance remains a part of the patient’s treatment plan.
Health care practitioners required to consult CURES include1:
- Allopathic or Osteopathic Surgeon
- Certified Nurse Midwife (Furnishing)
- Naturopathic Doctor
- Nurse Practitioner (Furnishing)
- Physician Assistant
Professional licensing boards have the authority to audit CURES activity to ensure compliance. Failure to comply could result in disciplinary proceedings against a practitioner’s license.
A health care practitioner is exempt from consulting the CURES database before prescribing, ordering, administering, or furnishing a controlled substance in any of the following circumstances:
1. While the patient is admitted to, or during an emergency transfer between a
2. In the emergency department of a general acute care hospital, and the controlled substance does not exceed a non-refillable seven-day supply.
3. As part of a patient’s treatment for a surgical procedure, and the controlled substance does not exceed a non-refillable five-day supply when a surgical procedure is performed at a
- Licensed Clinic, or
- Outpatient Setting, or
- Health Facility, or
- County Medical Facility, or
- Place of Practice
4. The patient is receiving hospice care.
The Medical Board of California has issued CURES Mandatory Consultation FAQs, located here.
1 This requirement does not apply to veterinarians or pharmacists.
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