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Compliance Corner: Clarifying CURES

Picture of Grant Miller, DVM, CVMA Director of Regulatory Affairs
Grant Miller, DVM, CVMA Director of Regulatory Affairs

 

This article was originally printed in the May/June 2026 issue of the California Veterinarian magazine.

There is ongoing confusion in the veterinary community about the registration and reporting obligations related to the Controlled Drug Utilization Review and Evaluation System/Prescription Drug Monitoring Program (CURES/PDMP). This system is overseen by the Department of Justice (DOJ) to curb diversion of Schedule II through V controlled substances. Many veterinarians have questions regarding CURES/PDMP. Some of the most common questions are answered in this article.

Who manages CURES/PDMP, and what is its purpose?

The CURES/PDMP system is regulated by the California DOJ and aims to curb controlled substance diversion by doctors who over-prescribe and individuals who “doctor-shop” or obtain controlled substances at pharmacies through abuse or alteration of a prescription. Although a common misconception, the Federal Drug Enforcement Agency (DEA) is not involved with CURES/PDMP, and therefore controlled substance logs kept in accordance with DEA regulations are a regulatory requirement separate from CURES/PDMP registration and reporting.

CURES/PDMP is an online database through which DEA license holders must report dispensed controlled substances on a weekly basis. Doctors may also review the controlled drug histories of their patients in this system.

Who is required to register with CURES/PDMP?

California Health and Safety Code section 11165.1(a)(1)(A)(i) states that all health care providers, including veterinarians, who possess both an active California license and a DEA registration must have registered with CURES/PDMP on or before July 1, 2016. Veterinarians must register as prescribers who are licensed under the California Department of Consumer Affairs. Registering with CURES is the only requirement that veterinarians have unless they dispense controlled substances to clients.

How do I register with CURES/PDMP?

Visit the CURES/PDMP.

Once registered with CURES/PDMP, what are the veterinarian’s obligations?

Per California Health and Safety Code section 11165(d), veterinarians who dispense Schedule II-V controlled substances to clients for use in animal patients must report specific information to the CURES/PDMP database within seven days. Required information includes the name, contact information, and date of birth of the animal owner, as well as select information about the controlled substance dispensed. If a veterinarian does not dispense controlled substances, they have no obligation to the CURES/PDMP other than registering as a practitioner.

How do I know if a drug is a controlled substance that needs to be reported?

All Schedule II-V controlled substances need to be reported. A current list of controlled substances can be accessed by clicking here

Where do I submit controlled substance dispensation reports?

The California DOJ contracts with Bamboo Health to develop and maintain an online reporting system called the PMP Clearinghouse. The online reporting platform may be accessed here.

Can a staff member log on to submit the report for the veterinarian?

Yes, but keep in mind that as the licensee, the veterinarian is ultimately responsible for ensuring the timeliness and accuracy of the reports.

Am I required to check a client’s controlled substance use history in the CURES/PDMP database prior to dispensing a controlled substance to them?

Veterinarians may opt to access the CURES/PDMP database to obtain the controlled substance history of a client, but are not mandated to do so. This exception contrasts with requirements for human health care providers, who are mandated to query the database the first time they provide a controlled substance to a patient.

Is it true that I don’t have to report controlled substance dispensations that are less than 48 hours in duration?

No. All Schedule II-V controlled substance dispensations by veterinarians must be reported to the PMP Clearinghouse within seven days.

Is it true that I need to file a “seven-day zero fill” report in the PMP Clearinghouse on a weekly basis even if I have not dispensed any controlled substances?

No, there is no legal requirement to complete a weekly “zero fill” report. While the DOJ would prefer that prescribers do so, it is not legally mandated and therefore unnecessary.

For more information on CURES/PDMP, visit cvma-watchdog.net and select “Regulatory Compliance,” then look for “CURES” in the Resources list on the right.

This article is for informational and general educational purposes only. It is not intended to take the place of legal advice, nor should it be considered as a legal interpretation. Although significant effort has been made to ensure the accuracy and completeness of the information at the time of publication, the CVMA shall not be responsible for any errors or omissions, or any agency’s interpretation, application, or enforcement of the information presented herein.

The CVMA-PAC

It’s Not About Politics….It’s About Your Profession. The CVMA-PAC is a bipartisan political action committee whose purpose is to educate state legislators and candidates on issues of importance to the veterinary profession

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