February 9, 2026 | Sacramento, CA — MedLegalNews.com — California health care providers must adjust compliance practices in 2026 following a significant statutory change affecting prescription reporting. AB 82, effective January 1, 2026, prohibits providers from reporting prescriptions or dispensing of testosterone and mifepristone to the Controlled Substance Utilization and Evaluation System (CURES), marking a notable shift in the state’s prescription drug monitoring framework.
What AB 82 Changes for CURES Reporting
Historically, CURES has served as California’s primary prescription drug monitoring program, requiring health care providers and pharmacies to report controlled substance prescriptions to support oversight, public health, and enforcement objectives. AB 82 narrows that reporting scope by expressly excluding testosterone and mifepristone, even when otherwise subject to tracking under prior rules.
This change reflects legislative intent to reduce unnecessary surveillance and administrative burdens related to medications with sensitive clinical, reproductive, and privacy considerations.
Compliance Impact for Physicians and Pharmacies
Physicians, pharmacists, and dispensing clinics should review internal workflows and electronic health record (EHR) configurations to ensure these medications are no longer transmitted to CURES. Failure to update automated reporting systems could result in inaccurate submissions and compliance risk.
While AB 82 removes reporting obligations for these drugs, all other controlled substance reporting requirements remain unchanged, including timelines, record retention, and access rules for authorized users.
Why Testosterone and Mifepristone Were Excluded
Lawmakers cited patient privacy, evolving standards of care, and concerns about data misuse as drivers behind the exemption. Mifepristone, in particular, has been the subject of heightened scrutiny nationwide, while testosterone prescribing often intersects with sensitive endocrine and gender-affirming care decisions.
The Legislature emphasized that removing these drugs from CURES does not legalize improper prescribing or dispensing, nor does it alter professional standards or enforcement authority under other state laws.
What Medical-Legal Stakeholders Should Do Now
Medical-legal professionals, compliance officers, and defense counsel should begin advising clients to update internal reporting protocols well ahead of the January 1, 2026 effective date. Clinical and administrative policies should be reviewed to ensure that prescriptions or dispensing of testosterone and mifepristone are no longer transmitted as part of routine CURES reporting, particularly where automated systems have historically defaulted to broader submission rules.
Stakeholders should also work closely with EHR vendors, pharmacy management platforms, and third-party reporting services to confirm that software-level exclusions are correctly implemented and tested. Reliance on outdated configurations may result in improper data submissions despite statutory changes, creating avoidable compliance exposure.
In addition, providers should train clinical and billing staff on the revised reporting boundaries so that day-to-day workflows reflect the new legal requirements. Clear internal guidance can reduce confusion during audits or inquiries and help demonstrate good-faith compliance efforts.
Finally, ongoing monitoring of implementation guidance from the California Department of Justice remains essential. Regulatory clarifications or technical advisories may follow as enforcement agencies adjust to the narrowed reporting scope. Failure to proactively align systems and practices with the new framework may expose providers to audit or compliance issues unrelated to patient care quality.
Visit the official DOJ CURES resource for authoritative compliance details and future advisories.
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FAQs: AB 82 and CURES Reporting
Does AB 82 eliminate all CURES reporting requirements?
No. The law only excludes testosterone and mifepristone. All other controlled substances must still be reported as required.
Are pharmacies still required to maintain records for these medications?
Yes. Standard pharmacy recordkeeping and licensing obligations remain in effect despite the CURES reporting exclusion.
Does this change affect prescribing authority or scope of practice?
No. AB 82 only addresses reporting to CURES and does not modify prescribing authority, scope-of-practice rules, or disciplinary standards.
Will CURES users still see historical data for these medications?
Historical data submitted before January 1, 2026, may remain accessible under existing CURES access rules, but new entries are prohibited.