CURES 2.0: Part 2

by Bruce Silver, MD

Since the last article about CURES 2.0, numerous questions have arisen, particularly as to what is a “facility.” Therefore, I will try to answer that question first.

The CURES 2.0 Program in California is mandatory beginning October 2, 2018.  The following are some of the regulations and policies that must be followed.  

Exceptions in Situations:  There are numerous exceptions to these rules including patients within the facility and certain exceptions for emergency room physicians.  A facility is defined per California regulations and appears to include most hospitals and nursing homes. A recent conference with the California Board noted that as far as nursing homes go, that while most of these may qualify as facilities, one needs to check the specifics of the nursing home.  Please check with the California Board to ascertain if the facility in which you are working is exempted.

It appears that people admitted to a nursing home or a skilled nursing facility are exempted while they are in that facility.

The CURES 2 database, it appears, must be consulted when writing a prescription for controlled substances upon discharge from said nursing home or skilled nursing facility. The people in charge have indicated that to be sure that a specific nursing home or skilled nursing facility is exempted, one should check that with the facility to make sure they are a “facility” under the definition as per the link below.

CURES stands for Controlled Substance Utilization Review and Evaluation System

         Controlled Substance

CURES is the prescription drug monitoring program for the State of California. CURES database contains information about schedule II, III, and IV controlled substance prescription dispensed to patients as reported by those dispensers.  

CURES data reflects dispensing information as it is reported to the Department of Justice.  The reporting dispenser creates and owns the prescription records submitted. The Department of Justice does not hold the prescription. 

The Health and Safety Code requires the Department of Justice to maintain the Controlled Substance Utilization Review and Evaluation System (CURES):

  1. To assist health care practitioners in their effort to ensure appropriate prescribing, ordering, administering, furnishing, and dispensing of controlled substances.
  2. To assist law enforcement and regulatory agencies in their effort to control a diversion and resultant abuse of schedule II, schedule III, and schedule IV controlled substances.
  3. For statistical analysis, education and research. 
CURES Mandatory Reporting
Health and Safety Code 11165, Subdivision (d)

The dispensing pharmacy, clinic, or other dispenser, including direct dispensing prescribers are required to report dispensations of schedule II, III, and IV controlled substances to Department of Justice, in a format specified by the Department of Justice, as soon as reasonably possible, but not more than seven days after the date a controlled substance is dispensed.

CURES Mandatory Registration

  1. All California licensed pharmacists, upon licensure.
  2. All California licensed health care practitioners authorized to prescribe, order administer, furnish or dispense schedule II, III, or IV controlled substances in California, upon receipt of federal DEA registration certificate.


Mandatory Use Requirement of SB-482:  With specified exceptions, a practitioner shall consult the CURES database no earlier than 24-hours, or the previous business day, before prescribing a schedule II-IV controlled substance to a patient for the first time, and at least every four months thereafter if the substance remains part of the treatment of the patient.  

Mandatory Use Requirement of SB-482 Definition of First Time:  “First time” means the initial occurrence in which a health care practitioner, in his or her role as a health care practitioner, intends to prescribe, order, administer, or furnish a schedule II, III, or IV controlled substance to a patient and has not previously prescribed a controlled substance to the patient.  

When Does Mandatory Use Become Effective: Mandatory use of CURES becomes effective on October 2, 2018.  

To Whom Does Mandatory Use Apply:  Prescribers with a DEA controlled substance registration certificate, schedule II-IV and a valid license issued by a professional state licensing board of the California Department of Consumer Affairs including Medical Physician, Optometrist, Osteopathic Doctor, Podiatrist, Naturopathic Doctor, Registered Certified Nurse Midwife, Physician Assistant, Registered Nurse Practitioner, and Dentist.  

This does not apply to veterinarians or pharmacists.  

Consequences of Non-Compliance with Mandatory Use: The responsibility of non-compliance goes to the respective state professional licensing board to determine administrative sanctions for health care practitioners who fail to consult the CURES database as required.  

Prescriber and dispenser registration must be done.  CURES registration can be found most easily by googling CURES 2.0 Registration.  A CURES registration must be completed online first and then an evaluation registration approval or denial will be sent via email within 24 to 48 hours.  

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