The Georgia PDMP

The Georgia Prescription Drug Monitoring Program (PDMP) is a favorite MPJE topic for one reason: it is a purely Georgia program with no federal twin. A candidate who studied only federal controlled-substance law walks into these questions blind. This deep-dive sits under our broader controlled substances overview, which is itself part of the guide to passing the Georgia MPJE.

The whole topic turns on one distinction the exam tests relentlessly.

Report vs. check — the distinction the exam is built around

Two different duties, two different people. Confusing them is the single most common PDMP error.

• Dispensers report. A pharmacy must submit every dispensed Schedule II–V controlled substance to the PDMP. This is a duty on the pharmacy/pharmacist.
• Prescribers check. The mandatory duty to query the PDMP before prescribing falls on the prescriber, not the pharmacist — and only for certain drugs.

So a Georgia pharmacist is required to report but is encouraged — not required by the PDMP statute — to check (O.C.G.A. § 16-13-63(a)(1)). If a question implies a pharmacist must query the PDMP before dispensing, that's the trap.

The rest of this article fills in each side.

Who runs it, and who has to enroll

The PDMP is administered by the Georgia Department of Public Health (DPH), in consultation with the Georgia Composite Medical Board, the State Board of Pharmacy, and the Georgia Drugs and Narcotics Agency (the "agency"). It records the dispensing of Schedule II, III, IV, and V controlled substances (O.C.G.A. § 16-13-57).

A detail worth knowing: every prescriber who holds a DEA registration number must enroll as a PDMP user (O.C.G.A. § 16-13-57(c)). A prescriber who obtains a DEA number now must enroll within 30 days of attaining it. Enrollment is on the prescriber; one who fails to enroll is administratively accountable to their licensing board.

The reporting duty (dispensers)

Each dispenser must electronically submit information on every Schedule II–V prescription dispensed (O.C.G.A. § 16-13-59).

• How often: at least every 24 hours — effectively daily (§ 16-13-59(b)). The CS overview phrases this as "within 24 hours"; the statutory language is "at least every 24 hours."
• What's reported: at least fifteen data elements per prescription (§ 16-13-59(a)):
  • the dispenser's DEA or facility ID number;
  • the date the prescription was dispensed;
  • the prescription serial number;
  • whether it's a new prescription or a refill;
  • the NDC of the drug dispensed;
  • the quantity and strength dispensed;
  • the days' supply;
  • the patient's name, address, date of birth, and gender;
  • the method of payment;
  • the prescriber's ID or DEA number;
  • the date the prescription was issued.
• Equipment failure: if a dispenser is temporarily unable to submit (equipment failure or similar), it must immediately notify the board and the department (§ 16-13-59(b)).
• Out-of-state pharmacies count. A pharmacy located in another state or country that ships, mails, or delivers a dispensed controlled substance into Georgia is a "dispenser" and must report (§ 16-13-59(g)).
• "Zero reports." If a pharmacy dispenses no controlled substances within a 24-hour period, it must still submit a report stating that fact — Ga. Comp. R. & Regs. r. 511-7-2-.03: "If no prescriptions are dispensed within a 24 hour period, then a report shall be made indicating that fact." (This is a DPH rule-level requirement; it is not stated in § 16-13-59 itself.)

Exemptions and waivers from reporting:

• Electronic-filing waiver (financial hardship). A dispenser that can't file electronically may ask DPH to report by another approved method — but it still submits every required field within the same 24 hours (§ 16-13-59(c)). DPH grants this only on proof the dispenser "lacks sufficient financial resources to arrange for electronic transmission on its own or by arrangement with a third party" (Ga. Comp. R. & Regs. r. 511-7-2-.05). Picture a dispenser that simply can't afford reporting software or a reporting service — the test is the money, not the pharmacy's size or volume.
• A broader exemption, on paper. Section 16-13-59(f) lets a dispenser apply to be excused from the reporting section altogether for undue hardship — but the statute leaves the criteria to DPH, and the only hardship rule in the PDMP chapter (511-7-2) is the electronic-filing waiver above.

The mandatory check (prescribers) — and exactly which drugs trigger it

Since July 1, 2018 — the date the duty took effect, once Georgia certified the PDMP operational — a prescriber must seek and review PDMP information the first time they prescribe a triggering drug to a patient, and at least once every 90 days thereafter while that prescribing continues (O.C.G.A. § 16-13-63(a)(2)(A)).

The trigger is narrower than "Schedule II." Not every controlled substance sets off the check — not even every Schedule II drug. Only two groups do: the Schedule II opioids and cocaine (hydrocodone, oxycodone, morphine, fentanyl, methadone — and cocaine itself) and any benzodiazepine. That's the whole list. (In the statute: the substances in § 16-13-26(1)–(2), plus benzodiazepines — § 16-13-63(a)(2)(A).)

Two clean, testable lines fall out of this:

• A Schedule II stimulant does not trigger the mandatory check. Amphetamine/mixed amphetamine salts (Adderall) and methylphenidate are Schedule II, but they are not in § 16-13-26(1)–(2), so the prescriber's 90-day check duty does not apply to them.
• A benzodiazepine does trigger it — even though benzodiazepines are Schedule IV. The statute names benzodiazepines specifically, independent of schedule.

For any other Schedule II–V controlled substance — one outside the opioid/cocaine list and not a benzodiazepine — the prescriber is not required to check (§ 16-13-63(a)(4)).

The five exceptions to the prescriber check

Even for a triggering drug, the mandatory check does not apply when (O.C.G.A. § 16-13-63(a)(2)(A)):

1. The prescription is for no more than a 3-day supply and no more than 26 pills;
2. The patient is in a hospital or healthcare facility (nursing home, intermediate care home, personal care home, hospice) where the drug is administered and used on the premises;
3. The patient had outpatient surgery at a hospital or ambulatory surgical center and the prescription is for no more than a 10-day supply and no more than 40 pills;
4. The patient is terminally ill or under the supervised care of an outpatient hospice program; or
5. The patient is receiving treatment for cancer.

Note the two numeric pairs — 3 days / 26 pills and 10 days / 40 pills — are both-prongs tests. Exceed either the day count or the pill count and the exception no longer applies.

The documentation duty

When a prescriber reviews the PDMP, they must record in the patient's chart the date, time, and name of the person who ran the search — and, if the PDMP could not be accessed, a notation to that effect with the same details (O.C.G.A. § 16-13-63(a)(3)).

Who can access the data

PDMP information is confidential and is not subject to Georgia's Open Records Act (O.C.G.A. § 16-13-60(a)). Access is limited to specific people and purposes (§ 16-13-60(c)):

• Prescribers and dispensers — but only "for the sole purpose of providing medical or pharmaceutical care to a specific patient." There is no general browsing.
• The patient, prescriber, or dispenser the information concerns — or that person's attorney — about their own records (§ 16-13-60(c)(2)).
• Delegates — capped at two. Under the staff-delegate rule, a prescriber or dispenser may delegate access to no more than two members of their staff per shift or rotation (§ 16-13-60(c)(5)); parallel provisions cover healthcare-facility and hospital-emergency-department delegates, each likewise capped at two per shift (§ 16-13-60(c)(6)–(7)). A delegate who misuses the data is criminally liable in their own right (a delegate is an "authorized" user under § 16-13-64) — and the delegating prescriber or dispenser may also be held civilly liable and criminally responsible for that misuse (§ 16-13-60(c)(5)(D)).
• Law enforcement — with a warrant. State or local law-enforcement and prosecutors get PDMP data only pursuant to a search warrant; federal officials need a warrant, grand-jury subpoena, administrative subpoena, or civil investigative demand (§ 16-13-60(c)(3)). The common misconception that police can pull PDMP data on demand is wrong.
• Regulatory boards and Medicaid for health-oversight purposes.
• Other states' PDMPs and EHR systems that meet equivalent security safeguards (§ 16-13-60(c)(8)) — the legal basis for sharing across state lines. And Georgia uses it: it connects to other states through the interstate PDMP hubs (PMP Gateway / InterConnect), and its sharing partners include states on Georgia's borders. So a Georgia prescriber's check — or a pharmacist's look — can surface a patient's recent out-of-state dispensing, not just Georgia fills; a border pharmacy isn't flying blind on a patient who filled across the line last week.

Retention: DPH may not let anyone access identifying prescription information more than five years after it was received, and must delete or de-identify it on an ongoing basis (O.C.G.A. § 16-13-59(e)).

The penalties

The PDMP statute has real teeth (O.C.G.A. § 16-13-64):

• A dispenser who knowingly and intentionally fails to report, or submits false information, commits a felony — one to five years in prison, a fine up to $50,000 per offense, or both — plus referral to the licensing board.
• A person who negligently misuses, releases, or discloses PDMP data commits a misdemeanor, escalating to a felony on a second or subsequent conviction.
• Intentional improper disclosure is a felony; the prison term and fine scale with the circumstances (§ 16-13-64(c)):
  • knowingly disclosing, in and of itself — one to five years in prison and a fine up to $50,000;
  • disclosing under false pretenses — the fine ceiling rises to $100,000 (the prison term stays one to five years);
  • disclosing for commercial advantage, personal gain, or malicious harm — two to ten years in prison and a fine up to $250,000.

Liability runs the other way too — but the two roles differ.

• A dispenser has no duty to check at all, and faces no civil, criminal, or administrative consequence for whether they did or didn't (§ 16-13-63(a)(1)).
• A prescriber does carry the mandatory-check duty, but a violation is enforced administratively by the licensing board — the statute creates no civil or criminal liability merely for having sought, or not sought, PDMP information (§ 16-13-63(a)(2)(C)).

The PDMP traps to watch

• Report ≠ check. Pharmacies report (every Sch II–V, at least every 24 hours). Prescribers check. The pharmacist's check is encouraged, not required by the PDMP statute.
• The check trigger is not all of Schedule II. It's the Schedule II opioid/cocaine narcotics of § 16-13-26(1)–(2) plus benzodiazepines — so a Schedule II stimulant (Adderall) does not trigger it, but a Schedule IV benzodiazepine does.
• Check required first time + every 90 days — not "every time."
• The exceptions are both-prong numeric tests. 3 days and 26 pills; 10 days and 40 pills. Exceed either limit and the exception no longer applies.
• Delegates are capped at two per shift. A delegate is liable for their own misuse — and the delegator may be held responsible for it too (it's not one or the other).
• Law enforcement needs a warrant (or, federally, a subpoena/CID) — not a bare request.

For the full controlled-substance picture, go back up to Controlled Substances on the Georgia MPJE; for the exam as a whole, start with the hub: How to Pass the Georgia MPJE.

Frequently asked questions

Does a Georgia pharmacist have to check the PDMP before dispensing? No. Georgia's mandatory-check requirement applies to prescribers, not dispensing pharmacists. Pharmacists are required to report dispensed Schedule II–V prescriptions and are encouraged, but not required by the PDMP statute, to check (O.C.G.A. § 16-13-63(a)(1)).

How often does a Georgia pharmacy have to report to the PDMP? At least every 24 hours, for every Schedule II–V controlled substance dispensed (O.C.G.A. § 16-13-59(b)). And in any 24-hour period when it dispenses none, it must still file a "zero report" saying so (Ga. Comp. R. & Regs. r. 511-7-2-.03) — so a report is due even on a day with no controlled-substance activity.

Which prescriptions trigger the prescriber's mandatory check? Schedule II opioids and cocaine narcotics (the substances in § 16-13-26(1)–(2)) and benzodiazepines. The prescriber must check the first time and then at least every 90 days.

Does prescribing Adderall trigger the mandatory PDMP check? No. Amphetamine products and methylphenidate are Schedule II, but they are not opioids/cocaine narcotics under § 16-13-26(1)–(2), so the 90-day mandatory check does not apply to them.

Do benzodiazepines trigger the check even though they're Schedule IV? Yes. The statute names benzodiazepines specifically, regardless of their schedule.

Can a prescriber or dispenser let staff run PDMP queries? Yes — either may delegate access to up to two staff members per shift or rotation; the rule applies the same way to a prescriber's and a dispenser's (pharmacy's) staff (O.C.G.A. § 16-13-60(c)(5)). If a delegate misuses the data, the delegate is criminally liable in their own right, and the delegating prescriber or dispenser may also be held civilly and criminally responsible for that misuse (§ 16-13-60(c)(5)(D)).

Can law enforcement pull PDMP data without a warrant? No. State and local officials need a search warrant; federal officials need a warrant, grand-jury subpoena, administrative subpoena, or civil investigative demand (O.C.G.A. § 16-13-60(c)(3)).

What happens if a pharmacy doesn't report? It depends on why. If something like an equipment failure makes reporting temporarily impossible, the pharmacy must immediately notify both the Board of Pharmacy and DPH (O.C.G.A. § 16-13-59(b)); handled that way, an outage is compliance, not a violation.

A pharmacy that deliberately refuses to report, or knowingly uploads false data, is a different story: that's a felony — one to five years in prison, a fine up to $50,000 per offense, or both — plus board action against the license (O.C.G.A. § 16-13-64(a)).

Sources

• O.C.G.A. Title 16, Chapter 13, Article 2, Part 2 — "Electronic Database of Prescription Information" (§§ 16-13-57 through 16-13-65), Georgia's PDMP statute:
  • § 16-13-57 — program, DPH administration, prescriber enrollment requirement
  • § 16-13-59 — dispenser reporting: data elements, "at least every 24 hours," waivers, undue-hardship exemption, out-of-state dispensers, 5-year retention
  • § 16-13-60 — confidentiality and access: care-of-a-specific-patient limit, two-delegate cap, law-enforcement warrant requirement, interstate sharing
  • § 16-13-63 — mandatory check: prescriber duty (first + every 90 days), the § 16-13-26(1)–(2)-plus-benzodiazepines trigger, the five exceptions, the documentation duty, dispenser non-liability
  • § 16-13-64 — criminal penalties for failure to report, false reporting, and misuse of data
  • § 16-13-26(1)–(2) — the Schedule II opioid/cocaine narcotics that define the check trigger
• Georgia PDMP — administration & reporting: Georgia Dept. of Public Health PDMP and Georgia Drugs and Narcotics Agency; Ga. Comp. R. & Regs. Chapter 511-7-2 (DPH PDMP reporting — r. 511-7-2-.03, dispenser transmission within 24 hours and the zero-report duty; -.04 delegates; -.05 hardship waiver).
• Composite Medical Board — Ga. Comp. R. & Regs. r. 360-38-.04 ("Requirements for Checking the PDMP"), implementing § 16-13-63 for prescribers.