By Michael Burger, Senior Consultant
Prescription drug monitoring programs (PDMPs) were created in 2002 as a tool to help address the growing problems of prescription drug abuse and diversion. PDMPs are independent, state-run databases of controlled substance prescriptions operated using supplementary funding through the Bureau of Justice Assistance (BJA). Until recently, PDMPs existed in relatively unknown, little-used silos. Of late, three things happened: 1) prescription drug abuse has emerged as a national epidemic, 2) technology has advanced, and 3) lawmakers at the federal and state levels have seized on the improvements in usability and technology available to access PDMPs. This was done through legislation, regulation and political will.
Electronic health record (EHR) vendors should be aware of PDMP activities and regulations to ensure their products are compliant with rapidly emerging federal and state requirements. By being proactive, vendors reduce the risk of being caught short and potentially losing revenue and market share.
Whats the fuss about? The root cause of these regulatory and legislative initiatives is that abuse and diversion of prescription drugs have reached epidemic proportions in the United States. Overdoses, in particular, are overwhelming police, health care workers and families in every state inner cities and suburbs alike. The numbers are staggering and heartbreaking. The Centers for Disease Control and Prevention reports that roughly 47,000 Americans or about 129 per day died from a drug overdose in 2014. Two-thirds of the overdose deaths involved opioids or heroin. Overdoses are the number 1 accidental killer of Americans 25 to 64 years old, surpassing even traffic deaths.
Recognizing that threat, federal and state lawmakers have stepped up regulatory and legislative mandates. All states (except Missouri) have established a PDMP. PDMPs collect data from dispensers such as pharmacies, outpatient hospital pharmacies, outpatient clinics and other submitters regarding quantities of and to whom controlled substance medications have been dispensed. Each state controls access to the database based upon purpose of access (such as law enforcement) and need to know.
In general, states encourage prescribers to check the PDMP before prescribing most controlled substances but do not impose a penalty for noncompliance. Some states, such as New York, require prescribers to check the database in advance before prescribing nearly all controlled substances.
The number of these mandates is growing. A challenge for prescribers is that PDMP access is typically via a standalone web portal, not a built-in feature of the EHR work flow. As demand for easier access grows due to regulatory requirements, EHRs should soon begin to be interoperable with individual states PDMP databases to both meet customer demand and regulatory compliance.
Five things EHR vendors should do now. State and federal policy makers have begun to recognize that its time to end the PDMP silos and make them more interoperable and useful in fighting the war against substance abuse. Here are five actions EHRs should take to prepare for integration with PDMPs.
1. Know whos in charge. Because PDMPs are state sponsored, a variety of state agencies are responsible for their administration. They include state boards of pharmacy, departments of health, law enforcement agencies, professional licensing agencies and substance abuse agencies. These various entities will be handling technical aspects that could impact how EHRs interact with PDMPs. EHR vendors need to know whos in charge in the states where their products are used so they can keep abreast of the evolving regulatory requirements concerning PDMPs.
2. What about the PMIX? PDMPs were created in a different environment than EHRs. As unique state-based initiatives, PDMP systems are developed using disparate tools and software to manage data. Some states contract with private-sector service providers to host or maintain their systems while others are developed in house. That lack of consistency, plus the lack of uniformity among state laws and policies, creates significant interoperability and interstate data-sharing challenges. Also, PDMPs use the Prescription Drug Monitoring Program Information Exchange (PMIX), which is an architecture for data sharing that is different than what is traditionally used by EHRs. Created by the BJA and the Office of National Drug Control Policy, PMIX is a national, interoperable architecture that supports the sharing of PDMP data within and across states by various hubs (such as PMP InterConnect®, RxCheck and RxSentry). EHR vendors need to be mindful of how their products will integrate with the PMIX architecture and related standards until the federal government promulgates a national interoperability standard. This standard could include the standards typically used for electronic prescribing and related transactions from HL7 and NCPDP. A new standard could be created, as well. Either way, it could take many years before such overarching standards are created and put in place.
3. Keep up with harmonization efforts. There are inherent differences in PDMPs from state to state, including how they may be accessed and how each uses PMIX to share data. Recognizing these differences and the challenges they present, the federal government has initiated standards and harmonization efforts through the S&I Framework (see the web page for more information). Pilots are under way in several states to test the use of NCPDP SCRIPT 10.6 and ASAP web services for supporting a PDMP/pharmacy hub. The results of these pilots will have implications for how EHRs integrate with PDMPs.
4. Check business agreements. As EHRs need to connect with PDMPs and share data, vendors may need to create or revisit business agreements with individual PDMPs and interstate data hubs. These agreements will need to address collection, use, privacy, disclosure, storage and other aspects of PDMP data exchange.
5. EPCS can help nip opioid abuse and doctor shopping in the bud. Electronic prescribing of controlled substances can be a useful tool to help prescribers identify potential substance abuse and doctor shopping before the PDMP is checked and prescriptions are written electronically through the EHR. Medication history often will provide valuable information about previous controlled substance prescriptions paid for by insurance as well as where they were filled. Such information can be used by a physician to initiate the necessary conversation with a patient about substance abuse. This makes EHRs a powerful adjunct tool to help prevent substance abuse and save lives. Its definitely a value-add from EHRs that physicians can get behind. Point-of-Care Partners can help you keep up with current events regarding PDMP, including state mandates and what needs to be done to integrate EHRs and PDMPs. For starters, check out our regulatory resource center, which makes it easy for you to stay current with state and federal regulatory actions.