Transcript Prescription Monitoring Program

Rachelle S. Mercier, Esq., MPH
November 6, 2015
PMP – What is it?
 A system that records schedule II-V medications that
patients have been prescribed and picked up from a
pharmacy. Prescription history is available from the past 12
months. The data is provided by all MA pharmacies and
any out-of-state pharmacies that delivery to MA.
 The PMP can help providers to make clinical decisions,
avoiding duplicating prescriptions, inappropriate drugdrug interaction, etc. It also can help to identify patients
who may be misusing or diverting controlled substances
and to offer substance use treatments to appropriate
patients.
Updates and Changes
 2014 Regulatory Changes
 Automatic Enrollment
 2015 – Law and Regulatory Changes
 DPH RFR
2014 DPH Regulatory Changes
Automatic Enrollment
 All providers are being automatically enrolled in the
PMP system when they apply for their MA Controlled
Substances Registration (MCSR) or seek renewal.
 2013: DPH started enrolling physicians, podiatrists,
dentists, and prescribing pharmacists.
 2015: APRNs and PAs
2014 DPH Regulatory Changes
Requirements for PMP Use
 Any provider enrolled in the PMP must consult the PMP system
prior to issuing a prescription to a patient for the first time:
 Sched. II or III narcotic drug;
 Benzodiazepine; or
 Additional medications (Sched. IV or V) as designated by DPH.
 Providers may need to consult the PMP each time they issue a
prescription for a Sched. II or III medication if:
 DPH finds the drug to be commonly misused or abused and it
needs additional safeguards.
 **DPH must convene an Advisory Group to develop this
guidance and hold a public hearing with public comment before
any drug is added to the list.
2014 DPH Regulatory Changes
Exceptions to PMP Use
 Exceptions to checking the PMP allowed under regulations:
 Practitioners who are only authorized to prescribe, administer, possess, order, or
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dispense samples of controlled substances in Schedule VI;
When providing care to patients who are in a hospice or inpatient facility;
Practitioners providing immediate and proper treatment in a single dose or in a dose
that is essential for the treatment of the patient, in accordance with M.G.L. c. 94C, §
9(b), that includes the administering of the drug during that treatment;
Where emergency care is required and, in the professional opinion of the prescriber,
use of the PMP is likely to result in patient harm.
Practitioners who treat patients in the emergency department and either
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(1) do not anticipate writing a prescription Schedules II-V drug during the ED visit, or
(2) do not prescribe more than a five-day supply a Schedules II-V drug;
 Practitioners who are unable to use the system due to operational/system level
failures;
 Practitioners who care for patients under 96 months of age;
 Where a practitioner has been granted a waiver (pursuant to 105 CMR 700.012(I));
and
 DPH may define other exceptions in guidance – none yet!
2014 Regulatory Changes
Delegates
 Delegates are allowed!
 Primary Account Holder may designate support staff to use
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PMP on their behalf.
Must have internal policy on delegate use of PMP
Responsible for delegate's proper use of PMP
Must update DPH within 1 business day if delegate is no
longer authorized
To obtain a delegate application, visit DPH’s Website.
Hospitals eventually will be eligible Primary Account
Holders for interns and residents to be delegates of the
hospital.
FAQ List & Need to Know
 New Forms:
 http://www.mass.gov/eohhs/gov/departments/dph/programs/hcq/drugcontrol/ma-online-prescription-monitoring-program/
 What is prescribing “for the first time”?
 When a patient hasn’t been prescribed a Sched. II or III narcotic or
benzodiazepine before from the individual prescriber OR from another
authorized prescriber belonging to the same practice group within the previous
12 months.
 Do I need to check the PMP before prescribing take-home medication for an
inpatient who has already been ordered that medication during their stay?
 Yes. Although there is an exception to using the MA Online PMP if you are an inpatient
provider, this exception does not apply when the prescriber is providing medication at
discharge or for use post-discharge. Under the regulations, a provider would be required
to check the MA Online PMP, even if the prescriber provided that medication to the
patient per medical orders. According to DPH, medical orders are not the same as a
prescription.
 If you find other scenarios that seem to fall into a gray area, please let
me know!
2015 Updates
 FY16 Budget Language - Section 89
 Amends M.G.L. Ch. 94C, §24A:
“…(c) For the purposes of monitoring the prescribing and dispensing of all
schedule II to V, inclusive, controlled substances and additional drugs, as
authorized in subsection (a), the department shall promulgate regulations
including, but not limited to, (1) a requirement that each pharmacy that
delivers a schedule II to V, inclusive, controlled substance or a substance
classified as an additional drug by the department to the ultimate user shall
submit to the department, by electronic means, information regarding each
prescription dispensed for a drug included under subsection (a); and (2) a
requirement that each pharmacy collects and reports, for each prescription
dispensed for a drug under subsection (a), a customer identification number
and other information associated with the customer identification number, as
specified by the department. Each pharmacy shall submit the information in
accordance with transmission methods and frequency requirements
promulgated by the department; provided, however, that the information shall
be submitted at least once every 24 hours7 days…”
 Hastens reporting for pharmacies to be within 24 hours (formerly 7
days)
2015 Updates
 DPH proposed regulations: 105 CMR 700.012(A)(5)
(5) The information required by 105 CMR 700.012 shall be transmitted to
the Department or its agent in accordance with any procedures
established by the Commissioner or designee by the end of the next
business day and shall include data for all controlled substances
dispensed since the previous transmission or report at least once
every seven days and no later than ten days after dispensing, or as
otherwise specified in guidelines of the Department, by use of
encrypted electronic device or electronic transmission method in a
format approved by the Commissioner or designee.
 Public hearing held on 09/18/15
 Final language (above) presented to PHC on 10/21/15
 Approved by PHC
Possible Upcoming Changes…
 Governor’s Opiate Legislation: HB3817
 Among other provisions not related to the PMP:
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It would require ALL prescribers to use the PMP before prescribing any opiate, amending MGL Ch.
94C, Sec. 24A as follows:
 “The department shall promulgate rules and regulations relative to the use of the prescription
monitoring program by registered participants, which shall include requiring participants to
utilize the prescription monitoring program prior to the issuance, to a patient for the first time,
of a prescription for a narcotic drug that is contained in schedule II or III. The department may
require participants to utilize the prescription monitoring program prior to the issuance, to a
patient for the first time, of benzodiazepines or any other schedule IV or V prescription drug,
which is commonly abused and may lead to physical or psychological dependence or which
causes patients with a history of substance dependence to experience significant addictive
symptoms. The regulations shall specify the circumstances under which such narcotics may be
prescribed without first utilizing the prescription monitoring program; provided, however,
that said regulations shall require every provider to use the prescription monitoring
program prior to prescribing an opiate. The regulations may also specify the circumstances
under which support staff may use the prescription monitoring program on behalf of a registered
participant. When promulgating the rules and regulations, the department shall also require
that pharmacists be trained in the use of the prescription monitoring program as part of the
continuing education requirements mandated for licensure by the board of registration in
pharmacy, under section 24A of chapter 112. The department shall also study the feasibility and
value of expanding the prescription monitoring program to include schedule VI prescription
drugs.”
Possible Upcoming Changes…
 Senate’s Substance Use Prevention Bill – SB 2022
 Among other provisions not related to the PMP:
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Would include gabapentin in the PMP
Use of PMP data for provider prescribing analysis
Would require it for any prescription of ER-LA opioid in a
non-abuse deterrent form
Would establish a non-opiate directive form that would be
recorded in EHRs and the PMP
Other Updates
 DPH is in the process of updating the PMP
 RFR was published this summer
 DPH is evaluating bids and vendors
PMP
Information and Troubleshooting
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DPH Drug Control Program (DCP) and Virtual Gateway (VG) websites:
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DCP Main Site: http://www.mass.gov/eohhs/gov/departments/dph/programs/hcq/drug-control/
DCP PMP Specific: http://www.mass.gov/eohhs/gov/departments/dph/programs/hcq/drugcontrol/ma-online-prescription-monitoring-program/
Virtual Gateway: http://www.mass.gov/vg
Credential retrieval/Log-in assistance
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VG Customer Service: M-F 8:30am-5pm
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Drug Control Program – 617-983-6700
Other issues
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Requires: user pin number (4 digits) and D.O.B.
Technical Assistance
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1-800-421-0983 or
617-847-6578 for TYY
www.mass.gov/vg/loginassistance
[email protected]
PMP Hotline: 617-753-7310
If all else fails…
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Rachelle Mercier at MHA
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[email protected]
781-262-6064
Thank you!
Questions?
Rachelle S. Mercier, Esq., MPH
[email protected]
781-262-6064