By Phil Walls, RPh, Chief Clinical and Compliance Officer, myMatrixx
A prescription drug monitoring program (PDMP) is a statewide electronic database of certain controlled substance prescriptions that have been dispensed in that state or into that state by an out-of-state mail order pharmacy. Accessible by law enforcement, prescribers and dispensing pharmacists, the database makes it possible to identify overprescribing of controlled substances, multiple providers treating the same patient, and other “red flags” such as doctor shopping and pharmacy shopping. Currently, 49 out of 50 states have regulations that require a PDMP; Missouri is the final holdout.
Speaking at the National Rx Drug Abuse Summit held in Atlanta last week, Joseph Rannazzisi, Deputy Assistant Administrator in the Office of Diversion Control at the Drug Enforcement Administration, cautioned that he has seen a migration of so-called pain management clinics out of Florida, following that state’s reforms in this regard, north to Georgia, Tennessee and other states. Without strict regulations in place, a state’s PDMP is the best tool available to combat the overprescribing of dangerous drugs like opioids by these clinics. Therefore, watch out Missouri–because while that state delays implementation of a PDMP, it runs a very real risk of becoming a target in this migration as the next pill mill of the nation.
When used appropriately, there is no doubt that PDMPs are an effective tool to curtail fraud, waste and abuse of dangerous controlled substances, and this topic was a recurring theme at the Summit last week. However, there are also limitations to the effectiveness of these programs, and therefore it is important to both identify those limitations and to develop corrective actions.
Since each state has developed its own PDMP, there are significant variations in the administration of these programs, including:
- The frequency of reporting which may vary between hourly, daily, weekly, bi-weekly and even monthly
- The type of controlled substances reported (schedules 2 through 5 or only those in schedules 2 and 3, or even 2, 3 and 4)
- The type of entity that is required to report, with some states having no requirement for dispensing physicians to report
- Differences in whether use of the database by prescribers and pharmacists is voluntary or mandatory
- Both real and perceived differences in the ease of use of the PDMP databases.
These variations mean that a state with mandatory use regulations, frequent (close to real-time) reporting among all dispensers, and data that is integrated into the electronic health record of the patient will have significantly better results than a state where participation is voluntary, reporting is delayed, use is cumbersome, and certain entities such as dispensing physicians are not required to report.
In addition to these variations between states, there are also concerns over state boundaries and who has access to the PDMP. States restrict prescriber access to individuals licensed in that state. This restriction becomes very problematic in cities that lie on state borders, such as Cincinnati. Without an agreement between states, a prescriber would not see prescriptions in his state’s database if the patient had the prescription filled in a pharmacy across state lines. Concerns also exist regarding restricted access to these databases. Current regulations do not allow insurance carriers or TPAs to utilize PDMPs to identify fraud, nor do they allow clinical pharmacists working for the payer or a pharmacy benefit manager (PBM) to have access. This latter restriction means that those health professionals charged with monitoring for compliance and safe drug use cannot use the most valuable tool available.
Part Two of this edition of Leaders Speak will take a look at innovative corrective action programs put in place by certain states as well as the National Association of Boards of Pharmacy. In addition, recommendations by Brandeis University’s Center of Excellence will be examined.
About Phil Walls
Phil Walls is the Chief Clinical and Compliance Officer for myMatrixx®, a leading pharmacy and ancillary benefit management firm focused on workers’ compensation. Phil oversees all aspects of myMatrixx’s clinical program and the corporately owned and operated mail service pharmacy. He is a clinical pharmacist with over 35 years of experience in pharmacy benefits management, healthcare informatics and workers’ compensation. Phil has particular expertise in pain management, side effects of medications and managing overutilization. He is a published author, frequent speaker and regular contributor to the myMatrixx Blog covering work comp topics. Phil received the 2011 Dorland Health People Pharmacist Award, a national honor of excellence presented to healthcare professionals. Additionally, he is a member of several industry organizations including the American Pharmacists Association and the National Council for Prescription Drug Programs. Phil received his Bachelor in Science in Pharmacy from Mercer University School of Pharmacy and was awarded Doctoral Candidate status in Pharmacology at Ohio State University.
About myMatrixx
myMatrixx® is a full-service pharmacy and ancillary benefit management company focused on the workers’ compensation market. By combining advanced technology, clinical expertise and comprehensive reporting, myMatrixx simplifies the management of claims. Our results driven solutions deliver reduced costs for our clients and improve outcomes for their injured workers.
Disclosure:
myMatrixx is a WorkCompWire ad partner.
This is not a paid placement.