What’s At Risk by Waiting to Integrate Multi-State PDMP Checks

By 2028, American mail-order pharmacies are projected to grow by nearly 20%, filling 1.3 billion prescriptions a year, up from 900 million in 2026.

Such a rise in demand is likely to strain an already fragmented health system. That’s why Bamboo Health and the National Association of Boards of Pharmacy (NABP) hosted a webinar on “Dispensing Safely at Scale: A Multi-State PDMP Playbook.” Mail-order and multi-state dispensing keep growing, and checking a prescription drug monitoring program (PDMP) is no longer a simple, single-state task. The gap between checking a box and reviewing the data is widening, and regulators are watching that gap closely.

PDMP administrators and experts shared their perspective on how to address the gap — before it shows up in an audit or contributes to an adverse patient outcome.

The Multi-State Risk Already Outpaces Manual Checks

Patients rarely stick to one pharmacy. In South Carolina, 23% of patients filled a controlled substance at more than one pharmacy last year. Of the roughly 120,000 patients who filled a prescription out of state, 61% also filled one in-state. Cost, convenience and insurance coverage can all push patients across pharmacy and state lines.

Cross-state searches also carry their own risks by creating an incomplete picture for clinical decision-making. A pharmacist searching across states may pull up the wrong patient. A “John Smith” in Alabama isn’t the “John Smith” in Florida, and a rushed match can pull the wrong history into a clinical decision. These moments could lead to a mismatched record or a missed drug interaction, meaning an incomplete PDMP check can turn into a real patient risk.

Regulators Are Watching Closely

Scrutiny is increasing at both federal and state levels. That shift puts more pressure on pharmacy operators to document and demonstrate they’re meeting their compliance obligations rather than relying on basic claims.

One of the panelists described corresponding responsibility laws at the federal level and, in some states, at the state level.

One recent example is pending litigation involving a Drug Enforcement Administration (DEA) order against a pharmacy addressing pharmacists’ longstanding “corresponding responsibility” under 21 C.F.R. § 1306.04.

The order also listed red flags the pharmacy allegedly ignored. These included high volumes of buprenorphine mono-product, dangerous drug combinations, and long-term high-dose opioids. It also cited signs of doctor or pharmacy shopping.  While the final legal decision is still pending, the matter illustrates how consistent PDMP use may support a pharmacy’s broader compliance processes and documentation.

Integration offers one way to close that gap before it ever becomes a finding. When pharmacists can access accurate data directly in their dispensing workflows, they gain a reliable, documented process to trace back to.

Manual Checks Can Create Operational Risk

Both regulators and pharmacy operators see the benefit of building PDMP checks into the daily workflow — regulators get consistent documentation, and operators get a process that doesn’t rely on any one person to remember every step under pressure.

Under enough real-world pressure, manual PDMP processes pose a real risk of inconsistency and impact on the patient. Any manual step is vulnerable to real-world delays like phone calls, patient issues, walk-ins, and more.

Many pharmacists must leave their dispensing system and log into a separate portal or manage credentials and search for each patient by hand. With integration, the PDMP report can be ready by the time a pharmacist reaches the drug utilization review step.

What to Do Now, Not Later

The panelists outlined what a multi-state dispenser should do differently:

• Start mapping your current PDMP workflow: Note who checks it, how, and where the manual decision points sit.
• Focus on education and adoption: Pharmacy operators can use the training their state PDMP programs already offer. That training helps pharmacists read reports correctly, even under pressure.
• Verify access with up-to-date credentials: Before integration, confirm your PDMP account credentials and data are current. Outdated logins or data will slow down any later multi-state expansion.
• Assess whether you or your pharmacists are spending more time reviewing the information or looking for it.

Frequently Asked Questions

1. What does “corresponding responsibility” mean for pharmacists, and how can PDMP checks help demonstrate it?
   Under 21 C.F.R. § 1306.04, pharmacists share responsibility with prescribers for ensuring that a controlled-substance prescription is issued for a legitimate medical purpose in the usual course of professional practice. A recent DEA order against a pharmacy cited potential red flags such as high volumes of buprenorphine mono-product and signs of doctor or pharmacy shopping. Consistent PDMP review can support a documented, repeatable process for evaluating relevant information, but it is only one part of a pharmacist’s broader compliance and professional responsibilities.
2. How do pharmacies avoid pulling the wrong patient’s history when searching across state lines?
   Building patient-matching into an integrated PDMP check, instead of relying on a pharmacist to confirm identity by hand under time pressure, cuts down the chance of a mismatched record slipping through.
3. What’s involved in integrating PDMP checks into an existing dispensing workflow?
   Integration means the PDMP report is already pulled and waiting by the time a pharmacist reaches the drug utilization review step, instead of requiring them to leave their dispensing system, log into a separate portal, and search by hand. Getting there starts with mapping your current workflow — who checks what, how, and where the manual decision points sit — then confirming your PDMP account credentials and data are current before layering in integration.
4. If a regulator asks, what documentation does an integrated PDMP check produce? Building PDMP checks into the daily workflow can create a more consistent, repeatable record of PDMP review rather than relying on a pharmacist to remember each manual step every time.
5. Does adding PDMP checks to the workflow slow pharmacists down? Manual PDMP checks can add time and inconsistency when pharmacists must leave the dispensing system, log into a separate portal, and search by hand. Integration can make the report available directly in the workflow and help save time.

Community pharmacies went through this shift years ago. Mail-order and multi-state dispensers are on the same path now, just moving faster and across more states at once. The pharmacies getting ahead of it are the ones treating PDMP checks as a workflow problem, not a login problem.

Still have questions about integrating PDMP data into your own workflow? Visit bamboohealth.com/nabpwebinar to connect with our team.

Sources: 2023 McKinsey Pharmacy Report; 2025 Mail Order Pharmacy Market Report