Implementation 12 min read

Texas Clinic Compliance Checklist (2026): PMP, Controlled Substances, and Prescribing Workflow

Texas clinic operations around controlled substances depend on disciplined PMP checks, prescribing governance, and auditable workflows. This checklist gives leaders a practical execution model.

Compliance + Vendor Evaluation Links

Texas Dates and Baseline Requirements

  • September 1, 2019: Texas law established mandatory PMP review obligations before prescribing opioids, benzodiazepines, barbiturates, or carisoprodol.
  • March 1, 2020: Prescribers were required to search the Texas PMP before prescribing those medication categories.
  • Dispensers report controlled-substance dispensing data to PMP no later than the next business day.

Checklist 1: PMP Search Reliability

  • Embed PMP check checkpoint in EHR prescribing workflow before signature.
  • Capture PMP search confirmation and timestamp in the chart.
  • Implement exception path with mandatory reason capture and compliance review.
  • Audit monthly by provider, medication class, and site.

Checklist 2: Controlled-Substance Prescribing Governance

  • Define prescribing protocol by specialty and risk tier.
  • Require treatment plan documentation for chronic controlled-substance use.
  • Standardize refill and early-refill exception handling across locations.
  • Use peer-review triggers for high-variance prescribing patterns.

Checklist 3: Delegation and Role-Based Controls

Texas guidance clarifies that prescriber delegates can support workflow tasks while prescribers retain responsibility for appropriate prescribing actions.

  • Map role permissions for intake, queue prep, and final prescribing steps.
  • Block unauthorized users from final controlled-substance actions.
  • Maintain annual policy attestation and workflow simulation training.
  • Track failed/overridden controls as reportable risk events.

Checklist 4: Leadership Dashboard

  • PMP check completion rate by provider and site
  • Controlled-substance exception count and aging
  • Refill turnaround and variance indicators
  • Denial or payer audit trends linked to prescribing documentation
  • Training completion and policy attestation rates

Operational 60-Day Reset for At-Risk Clinics

  • Week 1-2: baseline PMP compliance and identify top failure points.
  • Week 3-4: patch EHR prescribing paths and role controls.
  • Week 5-6: launch governance dashboard and exception board.
  • Week 7-8: complete provider remediation and re-audit.

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