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
- State Compliance Hub — Compare TX, CA, FL, NY, and IL checklists
- Best EHR for MAT Programs — Controlled-substance workflow fit
- Behavioral Health EHR Comparison — Shortlist by specialty and scale
- Ease EHR Review — AI-native BH workflow and reporting depth
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.