California PDMP Requirements: What Every Prescriber Needs to Know in 2025

Overview of California's CURES PDMP

California's Controlled Substance Utilization Review and Evaluation System (CURES) is the state's prescription drug monitoring program. Unlike many other states, California has some of the most stringent PDMP query requirements in the nation.

As of January 2025, all prescribers authorized to prescribe Schedule II, III, or IV controlled substances must register with CURES and comply with mandatory query requirements. This includes physicians, dentists, podiatrists, nurse practitioners, and physician assistants.

Mandatory Query Requirements

When You MUST Check CURES

California Health and Safety Code Section 11165.1 requires prescribers to consult the CURES database:

1. At least once every 4 months when prescribing a Schedule II, III, or IV controlled substance to a patient
2. Upon reasonable cause to believe a patient may be seeking controlled substances for non-medical purposes
3. Before prescribing opioids for the first time to a patient

The 4-month timeline is strict. If you last checked CURES on January 1st and see the patient again on May 2nd (more than 4 months later), you must check CURES again before prescribing.

Exemptions to the Requirement

You are NOT required to check CURES when:

• Prescribing a controlled substance for 3 days or less (72 hours or fewer)
• Prescribing to a patient in hospice care or receiving palliative care in a licensed facility
• Prescribing to a patient in an inpatient setting (hospital, skilled nursing facility)
• The drug is administered directly by the prescriber (e.g., in-office injections)
• The CURES system is unavailable despite reasonable attempts to access it (you must document this)
• You do not have internet access at the location of prescribing (rare exemption, requires documentation)

Documentation Requirements

California law requires you to document CURES queries. Best practices include:

• Note in the patient's medical record that you reviewed CURES
• Document the date of the CURES check
• Record any concerns identified from the CURES data
• Document actions taken if concerning patterns are found (e.g., referral to specialist, discussion with patient, decision not to prescribe)

Example documentation: "1/15/25 - CURES reviewed prior to prescribing hydrocodone-acetaminophen. No concerning patterns identified. Patient has filled only 2 opioid prescriptions in past 12 months, both from this provider."

Delegate Access and Support Staff

California allows prescribers to authorize delegate users to access CURES on their behalf. This is useful for:

• Medical assistants who can pull CURES reports before appointments
• Nurses who prepare patient charts
• Pharmacists in collaborative practice settings

However, the prescriber remains responsible for reviewing the CURES data before making prescribing decisions. You cannot delegate the review responsibility, only the access responsibility.

Integration with EHR Systems

Many electronic health record (EHR) systems now integrate with CURES, allowing you to:

• Pull CURES data directly into the patient chart
• Set automatic reminders when a CURES check is due (every 4 months)
• Document CURES checks automatically with timestamps

Check with your EHR vendor about CURES integration. Popular systems like Epic, Cerner, and Athenahealth offer California CURES integration.

Common Compliance Mistakes

Mistake #1: Not Checking Often Enough

Many prescribers check CURES at the initial visit but forget the 4-month requirement. If you prescribe controlled substances to a chronic pain patient every month, you must check CURES at least every 4 months.

Solution: Set calendar reminders or use EHR flags to alert you when a CURES check is due.

Mistake #2: Relying on Staff Without Personal Review

Some prescribers have staff print CURES reports but never personally review them before prescribing. This does not satisfy the legal requirement.

Solution: Make CURES review part of your prescribing workflow. Review the report yourself before writing the prescription.

Mistake #3: Not Documenting Exemptions

If you prescribe without checking CURES due to an exemption (e.g., 3-day supply), you should still document why you didn't check.

Solution: Note in the chart: "Prescribed 3-day supply of tramadol for acute pain. CURES check not required per HSC 11165.1(a)(2)(A)."

Mistake #4: Forgetting Out-of-State Data

CURES now includes data from many other states through interstate data sharing. Don't assume a patient with no California prescriptions has no controlled substance history—they may be filling prescriptions in Nevada or Arizona.

Solution: Review the full CURES report, including out-of-state prescriptions.

What to Look For in a CURES Report

When reviewing a CURES report, red flags include:

• Multiple prescribers: Patient receiving controlled substances from 3+ different prescribers
• Multiple pharmacies: Patient filling prescriptions at 4+ different pharmacies (possible "pharmacy shopping")
• Overlapping prescriptions: Patient has overlapping supplies of the same or similar medications
• High MME (morphine milligram equivalent): Daily opioid dose exceeding 90 MME
• Concerning combinations: Concurrent benzodiazepines and opioids without clear medical indication

If you identify red flags, consider:

• Discussing concerns with the patient
• Contacting other prescribers listed on CURES
• Referring to a pain management specialist
• Entering into a controlled substance agreement
• Declining to prescribe and offering alternative treatments

Penalties for Non-Compliance

The California Medical Board, Dental Board, Board of Registered Nursing, and Physician Assistant Board actively audit CURES compliance. Penalties include:

• Citations and fines up to $5,000
• Mandatory education on prescribing practices
• Probation with practice restrictions
• License suspension for repeated violations

In 2024, the Medical Board issued over 200 citations related to CURES non-compliance. This is a priority enforcement area.

How RX Agent Helps with California CURES Compliance

RX Agent provides instant answers to CURES questions:

• "Do I need to check CURES for a 2-day supply of Norco?" → Instant answer with HSC citation
• "How often do I need to check CURES for chronic pain patients?" → Clear 4-month timeline
• "What should I document after reviewing CURES?" → Best practice documentation templates
• "Are there CURES requirements for buprenorphine?" → Yes, it's Schedule III

Instead of searching through California regulations, get state-specific compliance answers in seconds.

Additional California Prescribing Requirements

CURES compliance is just one part of California's controlled substance regulations. Other requirements include:

• Security prescription forms for Schedule II prescriptions (if not using EPCS)
• Written consent for opioid prescriptions exceeding 90 MME daily
• CDC Guideline discussions with patients starting opioid therapy
• Naloxone co-prescribing recommendations for high-risk patients

RX Agent covers all California prescribing requirements, not just CURES.

Staying Up to Date

California PDMP requirements change frequently. Recent changes include:

• 2023: CURES integration with interstate data sharing (expanded coverage)
• 2024: Enhanced delegate access controls (security improvements)
• 2025: Planned integration with federal PDMP databases

Subscribe to updates from:

• California State Board of Pharmacy
• California Department of Justice CURES
• California Medical Board

Or let RX Agent monitor regulatory changes for you and provide real-time compliance updates.

Conclusion

California's CURES PDMP requirements are among the strictest in the nation, but compliance is straightforward with proper systems in place:

1. ✅ Register for CURES access
2. ✅ Check CURES at least every 4 months when prescribing Schedule II-IV substances
3. ✅ Document your CURES review in the patient's chart
4. ✅ Know the exemptions (3-day supplies, hospice care, inpatient settings)
5. ✅ Review CURES data before prescribing, don't just delegate to staff

Stay compliant, protect your license, and ensure patient safety by making CURES checks a routine part of your controlled substance prescribing workflow.