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Is Your Agency Ready For 2021’s Prescription Drug Monitoring Program (PDMP) Mandates?

The issue of Electronic Prescribing of Controlled Substances (EPCS) and Prescription Drug Monitoring Programs (PDMP) is of great importance to behavioral health providers. The federal government has mandated that every state have a PDMP database in place by January 2022, and states have either created them or set deadlines for participation by providers within their borders.

The need is very real. More than 130 people a day die from opioid-related drug overdoses, according to the Centers for Disease Control and Prevention (CDC). Physicians and pharmacists are in a position to help prevent opioid overuse and addiction, through prevention, education, communication, and the use of the right technologies at the right time. “Improving the way opioids are prescribed,” which includes “review of prescription drug monitoring program data” can help, advises the CDC.

This is why EPCS and the PDMP controlled substance database programs go hand in hand in the fight against opioid addiction and substance use disorder. Separately and together, they have a significant impact on the everyday practices of prescribers. They continue to be among the most promising state-level interventions to improve opioid prescribing, inform clinical practice, and protect patients at risk.

Download the Federal and State EPCS Deadline Onesheet.

 

What Is A PDMP?

As defined by the CDC, a PDMP is an electronic database that tracks controlled substance prescriptions in a state. PDMPs can provide health authorities timely information about prescribing and patient behaviors that contribute to the epidemic and facilitate a nimble and targeted response.

PDMPs are state-level electronic databases that track prescriptions of controlled substances. Authorized users can access prescription data such as medications dispensed and doses, to make visible when patients are “doctor shopping” to obtain opioids from multiple providers.

PDMPs enable prescribers to see data on controlled substances from multiple providers and give visibility to how many pharmacies a client is using. Integration into the clinical workflow and EPCS increases effectiveness and convenience.

 

Are PDMPs Effective?

Although findings are mixed, evaluations of PDMPs have illustrated changes in prescribing behaviors, use of multiple providers by patients, and decreased substance abuse treatment admissions. States have implemented a range of ways to make PDMPs easier to use and access, and these changes have significant potential for ensuring that the utility and promise of PDMPs are realized.

This overview of recent data released by the American Medical Association (AMA) shows how providers are using PDMPs tied to EPCS to fight the opioid epidemic, citing “more than 300.4 million Prescription Drug Monitoring Program (PDMP) queries in 2017 —a 121 percent increase from 2016 and a 389 percent increase from 2014.” This trend tracks a nationwide decrease in opioid prescribing for the fifth year in a row: Between 2013 and 2017, opioid prescriptions decreased by more than 55 million — a 22.2% decrease nationally.

“Checking your state’s PDMP is an important step in safer prescribing of these drugs,” according to this CDC PDMP Fact Sheet. PDMP data can help prescribers calculate the total amount of opioids prescribed by various providers per day while identifying patients who are being prescribed substances that may increase risk of opioid, which are added safety measures for the prescribing professional and the client.

 

Who Can Access A PDMP?

Many providers in both the acute care and behavioral health space have voiced privacy concerns with regard to PDMPs and their use. Both the CDC and states have taken stringent measures to ensure that the databases are protected by all that is required by HIPAA, as well as general safeguards around access and use. As electronic health record (EHR) systems are integrated into PDMPs for ease of use by prescribers, they too are required to meet strict access controls.

PDMPs are public health tools, and so have many uses across a range of users:

  • State health departments use PDMP data to understand the behavior of the epidemic and inform and evaluate interventions.
  • PDMPs can also be used to send “proactive” reports to authorized users to protect patients at the highest risk and identify inappropriate prescribing trends.
  • Prescribers are able to check a state PDMP prior to prescribing certain controlled substances and in certain circumstances.
  • Pharmacists are required to enter controlled-substances prescriptions into the state PDMP.

A note on PDMP data submission: Pharmacies submit prescription data to state PDMPs at varying intervals. Those can range from monthly to daily or even real time (less than five minutes). The efficacy of PDMP information is, therefore, somewhat tied to the timeliness of the data itself.

 

How Do PDMPs Help Fight The Opioid Epidemic?

“Prescription drug monitoring programs (PDMPs) are one of the most promising tools available to address prescription drug misuse, abuse, and diversion,” HEALTHIT.gov states. The combined use of EPCS and PDMP equips health care professionals to help prevent opioid abuse and save lives by making visible client and provider histories of prescriptions written and dispensed for controlled substances. The EPCS tool can reduce prescription pad theft for forged prescriptions, which can decrease the number of pills available on the street for illegal resale.

EPCS can also deter the activities of prescribers working at “pill mills,” which excessively prescribe and dispense controlled substances. PDMPs make visible to clinicians the activities of clients who visit multiple prescribers to obtain excessive prescriptions for controlled substances, for themselves or for illegal resale. Clinicians can act on this data to offer help for patterns of substance abuse, to save lives, and to interrupt the stockpiling of pills for resale on the street.

In one high profile pill mill case in 2019, made possible by enhanced visibility into prescribing and dispensing data, the US Department of Justice charged 41 individuals, including medical providers, clinic owners and managers, pharmacists, pharmacy owners, and managers and drug dealers and traffickers, with diverting approximately 23 million oxycodone, hydrocodone and carisoprodol pills.

 

History Of PDMPs

Although they are a hot topic today, PDMPs have been around for more than a century. According to an article in Pharmacy Times, the first PDMP was enacted by New York State in 1918 to monitor prescriptions for cocaine, codeine, heroin, morphine and opium. Then, as now, pharmacists were required to report copies of prescriptions to the health department within a set timeline (then 24 hours).

Jumping ahead to 2010, the U.S. Drug Enforcement Administration (DEA) published an interim final rule allowing for EPCS in all states. Its goals include:

  • Safer, faster, controlled substance prescribing
  • Allowing prescribers to do all prescribing from within an EHR system
  • 98.7% of U.S. pharmacies to be EPCS-enabled
  • EPCS now means a prescriber is ready to meet regulatory requirements
  • Reduction of fraud
  • Reduction in opioid use
  • Reduction in adverse drug events

Currently, 45 states have mandates in place for participation by a set deadline, while 49 states plus the District of Columbia have PDMP databases up and running.

Here is additional information regarding federal mandates for PDMP use:

 

EPCS And PDMP Regulatory Issues & Timelines

As with many other state and federal regulations and mandates, the COVID-19 pandemic created significant challenges to meeting PDMP and ECPS deadlines. Here is current information on significant federal legislation, and related implementation deadlines:.

1. 21st Century Cures Act Final Rule:

  • 21st Century Cures Act is about interoperability, information blocking, and the ONC Health IT Certification Program
  • ONC CERTIFICATION CRITERIA § 170.315(b)(3) Electronic Prescribing to NCPDP SCRIPT2017071
    – HIT Self-testing using the NCPDP Test Tool
    – Submit NCPDP Tool Validation Report to ONC-ACB
    – ONC-ACB validates and updates CHPL listing to include 2015
    – Edition Cures Update criterion for HIT
Deadline: Dec. 31, 2022

 

2. Script 2017:

This process lays the foundation for future improvements to a prescribing practice by achieving:

  • More robust interoperability
  • The ability for scripts to be adjusted electronically by a pharmacist, if necessary, via the Change Request functionality, which keeps all change documentation within the electronic record
  • More efficiency
  • Better patient/client satisfaction
  • Improves medication adherence

Goal:

Reduce provider and client/patient burden by improving authorization processes.

This process includes the following:

  • Requires payers to build payer-to-provider data sharing of claims and encounter data through FHIR APIs
  • Requires payer turnaround of 72 hours for urgent requests and 7 calendar days for standard prior authorization requests
  • Requires payers to include a specific reason for denials
  • Requires payers to publicly report data about prior authorizations

Impact:

  • Improved payer prior authorization turn-around time
  • Increase client/patient electronic access to health care information
  • The Federal Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act mandates the checking of the PDMP by certain Medicaid providers.
  • In 2019, a bonus measure to incentivize eligible providers to check the PDMP each time they prescribe a schedule II Opioid substance, beginning in 2019, is included as part of The Medicaid Medicare Access and CHIP Reauthorization Act (MACRA) program.
  • “Beginning October 1, 2021, states must have a qualified prescription drug monitoring program (PDMP) and must require that certain Medicaid providers check information about certain Medicaid beneficiaries’ prescription drug history in the qualified PDMP before prescribing controlled substances to the beneficiary,” according to The Federal SUPPORT Act, which includes Section 1944 (Medicaid Partnership Act). The FAQ from CMS on the SUPPORT Act offers additional detail.

3. EPCS:

EPCS. used in tandem with PDMPs, is seen by the federal government as a way to curb opioid abuse and also provide agencies with a way to track prescriptions and provider activity. Here is a breakdown of what EPCS legislation was designed to do:

Purpose:

A comprehensive bill designed to address the opioid abuse epidemic

Provision:

Requires providers to use EPCS for all schedule II-V prescriptions for Part D or Medicare Advantage Plans

Impact:

  • Providers with Medicare clients must be ready with and using an e-Prescribing solution.
  • SUPPORT Act provides CMS with the authority to, through rulemaking, enforce and specify appropriate penalties for non-compliance with the requirement for EPCS.
Effective: Jan. 1, 2021
Compliance: Jan. 1, 2022, with penalties to be decided by a future rule

 

EPCS And PDMP Mandates Are Permanent & Affect Core Business Operations For Behavioral Health

It is essential that behavioral health providers be aware that participation in PDMP databases and programs is mandatory in their state, as well as required by CMS. Not doing so will result in fines and penalties, affecting core business operations.

Why EPCS awareness matters:

  • EPCS is here to stay.
  • EPCS can help deter diversion and fraud.
  • EPCS can streamline clinician workflow.
  • EPCS can reduce patient burden.
  • EPCS can help healthcare providers directly integrate opioid prescription information into EHRs, which can enhance patient safety.

How can clinicians succeed with PDMP?

Clinicians may be wary of a database that exists outside their, or their agency’s, control. Taking note of the following can help clinicians succeed:

  • The PDMP is the source of truth
  • Checking the PDMP at the point of service is critical
  • Integrated PDMPs are more efficient
  • The right clinician has the right information at the right point of time to make the right decision
  • Be aware that penalties for not checking PDMP are forthcoming, including possible disciplinary action against the prescribing/dispensing practitioner’s license
  • PDMPs allow for an informed prescriber and an informed dispenser
  • Holds payers accountable to more timely dispensation with prior authorizations
  • Reduces the natural friction between payers and prescribers
  • Eliminates barriers to prescribing
  • Better patient/client satisfaction
  • Allows prescriber to be able to be completely transparent with the patient at the point of prescribing

 

How COVID-19 Has Affected The Mandates & Timelines Around EPCS And PDMPs

The COVID-19 pandemic created significant issues around the implementation of EPCS and PDMP processes (and compliance penalties) at the state and federal levels. Here are some aspects of what changed:

Waivers:

  • The federal government waived DEA registration requirements across state lines to facilitate provider license reciprocity and telehealth visits
  • Also waived were in-person visit requirements prior to initiating controlled substance drug therapy

Guidance:

  • Updated remote identity proofing guidance was issued for hospitals and clinicians
  • The use of EPCS and telehealth was strongly encouraged

Impact:

  • These actions removed barriers to telehealth and made it easier for providers to practice in additional states
  • These actions supported prescribing practices that limit exposure, enabling uninterrupted access to practitioners for clients/patients, and safeguarding their continued access to medications and controlled substances
Effective: Throughout the duration of the COVID-19 public health emergency

 

How Do PDMP Compliance Mandates Affect My State?

Wondering what the PDMP compliance deadline is for your state? Download our PDMP state deadline one-sheet.

To find more detailed information on PDMP programs and program contacts by state, you can visit the US Department of Justice’s PDMP Training and Technical Assistance Center.

 

You Can Reduce The Burden of PDMP Compliance With PDMP-to-EHR Integration

Prescribing agencies, such as behavioral health providers, who use an electronic health record (EHR) platform can greatly streamline their compliance process. An EHR can be configured, through built-in reporting modules or a third-party product, to collect the required documentation around prescribing and submit that electronically to databases as required by that state’s legislation.

Having an EHR with this capability is a tremendous time-saver. Rather than having to stop and access a separate workflow process to enter this information, the integrated EHR is able to pull the data required by the state PDMP and transmit it behind the scenes. Thus the agency remains in compliance, and staff/prescribers are not inconvenienced.

 

What Does the Future Hold For PDMP And EPCS?

Due to COVID and other factors, there remains much uncertainty around PDMP and EPCS as it affects behavioral health providers. Even so, there is strong agreement across the provider community that having these safeguards in place is well worth the time, effort and expenses. Why? It’s simple:

  • PDMPs offer insight to prescribers and help in identifying patterns in a patients record
  • PDMPs may help alleviate over-prescribing or fraudulent dispensing of medication
  • People in crisis can get much-needed help more swiftly and avoid disruptions in their medication
  • Medication refills can be accomplished without a trip to the prescriber’s office, leading to higher patient/client satisfaction

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