DEPARTMENT OF HEALTH AND HUMAN SERVICES 
Centers for Medicare & Medicaid Services 
7500 Security Boulevard, Mail Stop S2-26-12 
Baltimore, MD 21244-1850 
Frequently Asked Questions: 
SUPPORT for Patients and Communities Act, Section 5042  
Medicaid PARTNERSHIP Act 
On October 24, 2018, President Trump signed the Substance UseDisorder Prevention that 
Promotes Opioid  Recovery and Treatment for Patients and Communities  Act (SUPPORT for 
Patients and Communities  Act) into law (Pub. L. No. 115-271).  Section 5042 of the SUPPORT 
for Patients and Communities  Act includes the Medicaid Providers Are Required to Note 
Experiences in Record Systems to Help In-need Patients Act (Medicaid PARTNERSHIP Act), 
which added section 1944 to the Social Security Act (Act).  Under section 1944 of the Act, 
beginning  October 1, 2021, states must have a qualified  prescription drug monitoring  program 
(PDMP) and must require that certain Medicaid providers check information  about certain 
Medicaid beneficiaries prescription drug history in the qualified  PDMP before prescribing 
controlled  substances to the beneficiary. Below, CMS provides information  to states about 
implementing  section 1944 of the Act and about claiming  the 100 percent federal Medicaid 
matching funds for certain expenditures related to qualified PDMPs described in section 1944(f) 
of the Act.  The 100 percent federal match under section 1944(f) of the Act is available only for 
FY 2019 and FY 2020.  
1. How should states claim the 100% federal match available under section 1944(f) of 
the Act?
The Medicaid PARTNERSHIP Act did not specify any new processes for states with
respect to claiming  enhanced federal matching funds under section 1944(f) of the Act.  If
a state would seek enhanced federal match under section 1944(f) for expenditures on a
qualified  PDMP that is part of a mechanized claims processing and information  retrieval
system, as defined in 42 CFR 433.111(b),  then the prior approval requirements in 42 CFR
part 433, subpart C would apply.  Additionally,  prior approval requirements in 45 CFR
part 95, subpart F may apply, even if the requirements at 42 CFR part 433, subpart C do
not.
CMS expects many states would integrate their qualified  PDMPs with their existing
Medicaid mechanized claims processing and information  retrieval systems.  If states
choose to do so, they could potentially  receive 75 percent federal match for operation of
such systems under 42 CFR 433.116.  Similarly,  states that opt to integrate their qualified
PDMPs with their existing Medicaid mechanized claims processing and information
retrieval systems could potentially  claim 90 percent federal match under 42 CFR 433.112
for design, development,  installation,  or enhancement activities related to the qualified
PDMP that occurred after FY 2020, as described in State Medicaid Director Letter #18-
006.
CMS encourages states to submit with any applicable prior approval or advance planning
documentation  a plan for using the section 1944(f) federal matching funds that is likely  to help achieve the broader purposes of the SUPPORT for Patients and Communities  Act, 
such as by decreasing the amount of opioid-related  negative outcomes experienced by 
Medicaid beneficiaries. States should submit any applicable prior approval or advance 
planning  documentation to the appropriate state lead for Medicaid systems in the CMS 
regional office and should coordinate with Thomas Novak on discussing scope, 
expectations, and process (thomas.novak@hhs.gov).   
2. What kinds of activities can the enhanced match available under section 1944 of the
Act support?
Section 1944(f) of the Act establishes a 100 percent federal matching percentage for FY
2019 and FY 2020, for state expenditures to design, develop, or implement  a qualified
PDMP and to make connections to the qualified  PDMP.  For the 100 percent federal
matching percentage to apply, the PDMP must be qualified,  which means it must satisfy
the criteria described in section 1944(b)(1) through (2) of the Act.  Additionally,  the state
must have in place agreements with all contiguous  states to share certain qualified  PDMP
data, consistent with section 1944(f)(2) of the Act.
The criteria described in section 1944(b)(1) and (2) that a states PDMP must meet in 
order for the state to claim enhanced match are as follows:
1. The PDMP must facilitate access by covered providers to, at a minimum,  the
following  information  with respect to a covered individual,  in as close to real-
time as possible:
a. Information regarding the prescription drug history of a covered
individual  with respect to controlled substances.
b. The number and type of controlled substances prescribed to and filled
for the covered individual  during at least the most recent 12-month
period (data on prescribed and filled  medication  may be two data
sources).
c. The name, location,  and contact information  (or other identifying
number selected by the state, such as a national provider identifier
issued by the CMS National Plan and Provider Enumeration System)
of each covered provider who prescribed a controlled  substance to the
covered individual  during at least the most recent 12-month period.
2. The PDMP must also facilitate the integration  of the information  described in
(1) into the workflow of a covered provider,  which may include the providers
electronic prescribing system for controlled substances.
State expenditures on a qualified  PDMP that can be matched at 100% under section 
1944(f) of the Act could include expenditures on certain PDMP features that, in CMSs 
view, are consistent with section 1944s description of qualified  PDMPs.  A non-
exhaustive list of potential expenditures on a qualified  PDMP for which a state could  seek enhanced federal match under section 1944(f), subject to CMS review, might 
include the following: 
 State expenditures to design, develop, or implement  PDMP functionality  that will 
enable connections between the qualified  PDMP and providers Electronic
Prescriptions for Controlled  Substances (ePCS) systems, or that will enable
connections between the qualified  PDMP and other provider electronic health
records systems that might include prescription history information  (because
section 1944(b) describes monitoring  the prescription of controlled  substances
and facilitating  integration  of the PDMP with provider workflow, including  ePCS
systems).
 State expenditures to design, develop, or implement  systems or enhancements to
existing systems which support the reporting described in section 1944(e)(1), if
these expenditures can be cost-allocated to the qualified  PDMP rather than to the
states implementation  of section 1927 of the Act.
 If the qualified  PDMP is part of the states Medicaid mechanized claims
processing and information  retrieval system, state expenditures to design,
develop, or implement  systems or enhancements to existing systems that support
any reporting that might be required under 42 CFR 433.112(b)(15),  if those
expenditures can be cost-allocated to the PDMP.
 State expenditures to design, develop, or implement  upgrades to the functionality
of a states current PDMP, in order to ensure that it meets the statutory definition
of a qualified  PDMP.
 State expenditures to design, develop, or implement  functionality  to support the
data sharing that section 1944(b) of the Act permits, but does not require, between
a state Medicaid program or state Medicaid managed care entity and a qualified
PDMP.
CMS will  not, however, match state expenditures on provider-administered  or provider-
owned systems under section 1944(f) of the Act.  Section 1944 of the Act clearly requires 
that, to be federally matched at 100%, expenditures must be a states expenditures on a 
PDMP administered by the State.   
We encourage states to contact thomas.novak@hhs.gov  if they have questions about 
whether specific types of expenditures could be federally matched at 100% under section 
1944(f) of the Act. 
3. What kinds of information would CMS encourage states to include in any
applicable prior approval materials submitted to CMS?
CMS asks states to include the following  information  in any advance planning
documentation about activities under section 1944 that they provide to CMS.  At a
minimum,  the information  described in (4), (5), and (8) below should be included in any
applicable advance planning  documentation submitted to CMS.  All other information listed below is not required to be included  in advance planning  documentation,  but CMS 
encourages states to submit it, as it would help CMS to understand how the state is 
implementing  section 1944.  States should be aware that some of the other information 
might be requested by CMS as part of a post-claim review or audit.  
1. State has defined which health care providers are covered providers, consistent
with the definition  in section 1944(h)(3) of the Act.
2. State has defined, consistent with section 1944(a)(1) of the Act, the timing,
manner, and form under which a covered provider is required to check the
qualified  PDMP before prescribing a covered individual  a controlled substance.
For example, the state could show it has defined which Medicaid providers must
query a qualified  PDMP, for which beneficiaries they must do so, and under what
circumstances they must do so.
3. For providers that make a good faith effort to check a qualified  PDMP but cannot, 
we encourage states to describe what kinds of paper or electronic documentation
the state would require to confirm that a good faith effort was made, consistent
with section 1944(a)(2) of the Act.
4. States Requests for Proposals (RFPs) (HHS sole source requirements and
guidance may apply), contracts, IAPDs, or other documentation  (as applicable)
demonstrate that the system will be a qualified  PDMP as defined in 1944(b) of the
Act, because it will  facilitate access by a covered provider to, at a minimum,  the
following  information  with respect to a covered individual,  in as close to real-time
as possible:
a. Information regarding the prescription drug history of a covered individual
with respect to controlled  substances.
b. The number and type of controlled substances prescribed to and filled  for
the covered individual  during at least the most recent 12-month period
(note that data on prescribed medication and filled medication may be
two data sources).
c. The name, location,  and contact information  (or other identifying  number
selected by the state, such as a national provider identifier  issued by the
CMS National Plan and Provider Enumeration System) of each covered
provider who prescribed a controlled substance to the covered individual
during at least the most recent 12-month period.
5. State demonstrates that the qualified  PDMP will facilitate the integration  of the
information  described in (4) above into the workflow of covered providers, which
may include the providers electronic prescribing system for controlled
substances.
6. State has described whether there is a data sharing agreement in place between the
qualified  PDMP and the pharmacy director or medical director of the State
Medicaid agency and whether the qualified  PDMP will be capable of facilitating
that connection. 7. State has described whether it is choosing to facilitate access between the
qualified  PDMP and the medical director or pharmacy director of any managed
care entity.
8. State has documented that it has in place agreements with all contiguous states
that meet the criteria described in section 1944(f)(2) of the Act, or has submitted
preliminary  information  about these agreements and attested that the agreements
will be in effect before the state claims any enhanced federal matching funds
under section 1944(f) of the Act.
4. If the regulations at 42 CFR part 433, subpart C apply, how could a state ensure
that its qualified PDMP aligns with and incorporates industry standards, consistent
with 42 CFR 433.112(b)(12)?
We encourage states to refer to the information  on standards in SMD Letter #18-0061
and also to refer to the Interoperability  Standards Advisory (ISA) published  by the Office
of the National Coordinator for Health Information Technology  (ONC). Specifically,  the
section of the ISA describing  A Prescribers Ability  to Obtain a Patients Medication
History from a Prescription Drug Monitoring  Program,2 describes recommended
industry standards for PDMP and electronic health records (EHR) integration.  We also
encourage states to take a standards-based approach to the electronic prescribing of
controlled  substances, interstate data sharing of PDMP data, and electronic case
reporting, and to refer to the ISA as appropriate to learn more about those industry
standards.
5. In the existing process for complying with 42 CFR 433.112(b)(15), states provide
CMS with benchmarks and metrics on outcomes associated with enhanced match.
For states establishing qualified PDMPs that would be subject to 42 CFR part 433,
subpart C, what information specific to qualified PDMPs does CMS expect states to
submit with their prior approval documentation?
State RFPs (HHS sole source requirements and guidance may apply), contracts, IAPDs,
or other documentation (as applicable) should clearly require that the qualified  PDMP
support the reporting requirements described in section 1944(e)(1) of the Act, so that the
state would be able to include in its reports under section 1927(g)(3)(D) of the Act,
beginning  with reports submitted for 2023, the following  information  for the most recent
12-month period:
 The percentage of covered providers (as determined pursuant to a process established
by the state) who checked the prescription drug history of a covered individual
1 https://www.medicaid.gov/federal-policy-guidance/downloads/smd18006.pdf 
2 https://www.healthit.gov/isa/allows-a-prescriber-request-a-patients-medication-history-a-state-prescription-drug-
monitoring   through a qualified  PDMP described in section 1944(b) of the Act before prescribing 
to such individual  a controlled substance. 
 Aggregate trends with respect to prescribing controlled substances such as
the quantity of daily morphine milligram  equivalents prescribed for controlled
o
substances;
the number and quantity of daily morphine milligram  equivalents prescribed
o
for controlled  substances per covered individual;  and
the types of controlled substances prescribed, including  the dates of such
o
prescriptions,  the supplies authorized (including  the duration of such
supplies),  and the period of validity  of such prescriptions,  in different
populations  (such as individuals  who are elderly, individuals  with disabilities,
and individuals  who are enrolled in both Medicaid and Medicare).
 Whether or not the state requires (and a detailed explanation  as to why the state does
or does not require) pharmacists to check the prescription  drug history of a covered
individual  through a qualified  PDMP described in section 1944(b) before dispensing
a controlled  substance to such individual.
 An accounting of any data or privacy breach of a qualified  PDMP described in
section 1944(b), the number of covered individuals  impacted by each such breach,
and a description of the steps the state has taken to address each such breach,
including,  to the extent required by state or Federal law or otherwise determined
appropriate by the state, alerting any such impacted individual  and law enforcement
of the breach.
In the event states already have systems that can support such reporting requirements, 
states should reach out to their CMS regional office state officer for systems to discuss 
cost allocation. 
6. If 42 CFR 433.112(b)(15) applies to the states qualified PDMP, what transaction
data, reports, and performance information should the PDMP be able to produce?
In addition  to expecting states to develop PDMPs that will be capable of meeting the
reporting requirements at section 1944(e)(1), CMS also encourages states to develop
qualified  PDMPs that would be capable of reporting on the measures described below,
for purposes of 42 CFR 433.112(b)(15).  CMS has consulted with the Centers for Disease
Control and Prevention and has determined that if state PDMPs are able to report on
these measures, that would contribute to program evaluation,  continuous improvement  in
business operations, and transparency and accountability,  consistent with 42 CFR
433.112(b)(15):
1. Concurrent Use of Opioids and Benzodiazepines:  The percentage of individuals
18 years with concurrent use of prescription opioids  and benzodiazepines  for
30 cumulative days (excludes patients in hospice care and those with cancer). 2. Use of Opioids  at High Dosage in Persons Without Cancer: The percentage of
individuals  18 years of age who received prescriptions for opioids  with an
average daily dosage of 90 morphine milligram  equivalents (MME) over a
period of 90 days (excludes patients in hospice care and those with cancer).
3. Use of Opioids  from Multiple  Providers in Persons Without Cancer: The
percentage of individuals  18 years of age who received prescriptions for opioids
from 4 prescribers and 4 pharmacies within 180 days (excludes patients in
hospice care and those with cancer).
4. Use of Opioids  at High Dosage and from Multiple  Providers in Persons Without
Cancer: The percentage of individuals  18 years of age who received
prescriptions for opioids  with an average daily dosage of 90 morphine  milligram
equivalents (MME) over a period of 90 days AND who received prescriptions
for opioids  from 4 prescribers AND 4 pharmacies within 180 days (excludes
patients in hospice care and those with cancer).
5. The rate of events among individuals  receiving prescription  opioid  medications
captured via electronic case reporting as described in 45 CFR 170.315(f)(5) that
have evidence of opioid-related  hospitalizations,  emergency department visits,
and/or urgent care visits, expressed as number of unique events per month.
States should also consider if PDMP systems might also be leveraged to meet the 
Medicaid Drug Review and Utilization  requirements in Section 1004 of the SUPPORT 
for Patients and Communities  Act and specifically  discuss with CMS which enhanced 
matching rate might be available,  based on systems currently in place or that may be 
planned for design, development,  or implementation.   
7. How should states implement the requirement in section 1944(f)(2) of the Act to
have agreements governing sharing of qualified PDMP data with contiguous states?
As a condition  of receiving enhanced matching funds under section 1944(f) of the Act the
administering  state must [have] in place agreements with all States that are contiguous
to such administering  State that, when combined,  enable covered providers in all such
contiguous  States to access, through the [PDMP], the information  that is described in
[section 1944(b)(1)] of covered individuals  of such administering  State and that covered
providers in such administering  State are able to access through such program.  Section
1944(f)(2).  Therefore, before submitting  claims for enhanced federal match under
section 1944(f), states must be able to demonstrate that the required agreements are in
place.  If states are subject to prior approval requirements (such as under 45 CFR part 95,
subpart F, or under 42 CFR part 433, subpart C), they could include in the prior approval
materials a letter of intent to enter into the required agreements with final agreements to
follow,  and an attestation that the agreements will be in effect before the state claims any
enhanced federal matching funds under section 1944(f) of the Act. States that will integrate their qualified  PDMPs with their existing Medicaid mechanized 
claims processing and information  retrieval systems should refer to SMD Letter #18-006, 
which recommends states also refer to the Interoperability  Standards Advisory (ISA) 
published  by ONC. Specifically,  the section of the ISA describing A Prescribers Ability 
to Obtain a Patients Medication History from a Prescription Drug Monitoring  Program, 
discusses industry standards for interstate data sharing of PDMP data.  
8. What if a states existing PDMP does not allow data sharing with the state Medicaid
agency?
The section 1944(b) definition  of qualified  PDMP permits, but does not require, that a
qualified  PDMP facilitate data sharing with the state Medicaid program.  Specifically,  A
qualified  [PDMP] described in [section 1944(b)], with respect to a State, may have in
place, in accordance with applicable  State and Federal law, a data-sharing agreement with
the State Medicaid program that allows the medical director and pharmacy director of
such program (and any designee of such a director who reports directly to such director)
to access the information  described in [section 1944(b)(1)] in an electronic format.
While data sharing with the state Medicaid program is not required, states may find it
difficult  to leverage Medicaid to address the opioid  crisis without allowing
communications  between states qualified  PDMPs and their Medicaid programs.