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About tsullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

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Mar
14
2014

On Wednesday, I shared my thoughts on privacy and interoperability with the HIT Standards Committee’s Privacy and Security Workgroup. As the Chair of the U.S. Department of Commerce Healthcare Industry Committee that deals with emerging strategies for “Trusted Identities in Cyberspace” I have a front row seat, so to speak, on the issues facing the healthcare community on these topics. In essence, I expressed my belief that the nexus of privacy and interoperability surrounding identities is one of our most pressing concerns when it comes to healthcare technology.

You can read my full comments here: http://www.healthit.gov/facas/sites/faca/files/PSWG_Testimony-Tom%20Sullivan_2014-03-12.docx

About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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Jan
21
2014

Much has changed in the prescriber and the clinical IT vendor communities since the DEA issued the Interim Final Rule in early 2010, making electronic prescribing for controlled substances (EPCS) legal at the federal level. For instance, the White House’s decision to highlight the controlled substance drug abuse epidemic and crisis has spurred state legislators and regulators to pass new laws and strengthen existing regulations, such as the regulations that govern the state PDMP registries mentioned in earlier installments of this series. Some of the most far reaching changes have resulted in significant new obligations on physician practices, as well as EHR and EPCS vendors.

Prior to the 2010 IFR, it was generally the responsibility of the dispensing pharmacy to act as the first line of defense in detecting and addressing fraud, abuse, and diversion through strict reporting rules, in addition to its obligation to contact providers or their offices should questions arise over a given prescription. The requirement for detailed, organized audits, paper record keeping, and other protocols had already been in place for some time. The arrival of EPCS has added a series of new responsibilities to physicians and their software vendors. These new responsibilities include: very strict third-party identity proofing, new requirements for 2-factor authentication (often including a “hard token”), certification of the vendor application, and comprehensive electronic audit trails.

In addition to those federal requirements, some states have recently updated their PDMP to near-real-time reporting and secure web availability for all dispensed controlled substance drugs. New York in particular has enacted and recently implemented a mandatory “Duty to Consult” law, though certain waivers are permitted. I expect this will have a significant—and largely beneficial—impact over the next year and beyond, and will do much to help address the controlled substance problems in the state of New York.

Nevertheless, state authorities need to recognize the importance of working with the healthcare IT industry to minimize “the number of clicks” necessary to utilize any given technological solution, while also accomplishing the laudable objective of helping to curb abuse and illegal diversion of controlled drugs. It’s my opinion that these new regulations, along with other trends, have a potential downside in the form of disruptions to physicians’ workflows that could hamper productivity and efficiency across the healthcare industry.

Over the past 20 years, physicians have been paying much greater attention to workflow efficiency. There are so many interruptions and nonclinical obligations in most physicians’ offices today that a large percentage of practicing doctors have become angry and frustrated with a healthcare system that limits the amount of time that they devote to direct patient care. Unfortunately, these frustrations have been exacerbated by recent clinical information technology incentives, penalties, and software requirements that distract these highly-trained individuals from making the best use of their time. The time that physicians spend wrestling with technology is time they cannot spend with their patients. In fact, it is well documented that the burnout rate for physicians is approaching 30-40%, an unacceptable and astonishingly high rate. Clinical IT requirements, healthcare IT usability, and the demands on physicians’ time are all contributing factors to the high burnout rate among doctors, especially among more experienced practitioners, who did not grow up with computers and the Internet.

For these reasons, it’s extremely important that every mandate, incentive, and penalty for clinicians is carefully considered and implemented only after the completion of credible pilot programs. Additionally, there must be a mechanism for constructive feedback, and in some cases delays in deadlines when physicians, their organizations, and the vendor industry have demonstrated the need to make changes to newly instituted statutory programs.

DrFirst has been a proactive leader at both the regional and national levels in designing clinician-oriented, workflow-optimized, and easy-to-use healthcare software designs. We also have a strong history of collaboration with legislators and regulators as they craft new policies and regulations, helping to educate them about the importance of efficient workflow.

In fact, when asked to give a presentation last year to Dr. Farzad Mostashari, former director of the ONC, as well as his sub-committee, I reminded Dr. Mostashari of the wisdom behind what is widely accepted as the first rule of patient care, namely: “Primum Non Nocere” meaning “First of All, Do No Harm.”

Given the observations mentioned above I suggested a contemporary, new rule, namely: “Secundum, Tardus Ne Me,” which, translated from the Latin, means “Second of All, Don’t Slow Me Down.”

I hope that the brief humor generated by that comment, which was instantly Tweeted by Dr. Mostashari, will remind legislators, regulators, software designers, and policy makers that workflow efficiency is a serious industry concern.

  1. The Controlled Substance Epidemic and Crisis
  2. PDMP – What is it?
  3. EPCS – What’s New?
  4. Which one is more important…PDMP versus EPCS?
  5. The Physician and prescriber role in Controlled Substance Fraud and Abuse
About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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Dec
12
2013

In light of CMS’s recent announcement that it has decided to delay the onset of Meaningful Use Stage 3 until 2017, the first question everyone seems to be asking has been: how does this affect providers and MU Stage 2? The short answer is there probably will not be many, if any, immediate or impactful changes for the great majority of providers in small to medium ambulatory clinical practices.

However, this is a qualified “win” for vendors, data analysts who work at the ONC and CMS, and selected large hospital based health systems. Hospital based systems, in addition to a large number of stakeholders across all of the affected industries, have advocated for a delay in the start of Stage 2 (which began in October of this year for hospitals) rather than just an extension. Stage 2 will still start in January for all other affected medical professionals such as physicians or eligible providers.

Over the past 6 to 12 months, major industry and professional organizations such as CHIME, the AHA, the AMA, the AAFP, the ACP, HIMSS, and MGMA have joined a large number of senators advising that CMS and the ONC delay Stage 2. Many providers have found it incredibly difficult to successfully implement Stage 1 requirements within their workflow without having productivity suffer. These providers are increasingly concerned about their practices’ abilities to efficiently adapt to the more technical and secure patient communication requirements of MU Stage 2.

Only three percent of vendors have successfully certified for Stage 2 as recently as October of this year, which reflects the sheer amount of time and effort that certification requires for the healthcare IT industry. Delaying Stage 3 until 2017 demonstrates that CMS wants to avoid any further issues going forward and wants to give the healthcare IT industry, among others, enough time for research and development to get Stage 3 right from the beginning. Both the IT industry and the analysts at CMS and the ONC will now have additional time to examine what is working and what is not. This will be most helpful for CMS itself as they determine how much more everyone will be “pushed” to adopt more stringent requirements that promote interoperability, the use and documentation of clinical quality measures and more secure, clinical communications particularly through the Direct Project protocols (especially with patients, not just with providers).

The delay in the onset of Stage 3 will help propel IT vendors into a stronger position of readiness. This will also help providers, as they will not have to face the potential of lost incentive money or worry about the possibility of penalties as their EMR systems attempt to satisfy CMS’s stringent requirements.

CMS has also announced that an additional option set of Meaningful Use Stage 3 certification standards will be developed in an effort to help keep Stage 3 responsive to the dilemmas providers encounter over the course of navigating Stage 2 of the program. According to their press release, CMS will release “proposed rulemaking (NPRM) for Stage 3 and corresponding ONC NPRM for the 2017 Edition of the ONC Standards and Certification Criteria…in the fall of 2014, which will outline further details for this proposed new timeline. The final rule with all requirements for Stage 3 would follow in the first half of 2015. All stakeholder comments will be reviewed and carefully considered before the release of the final rules.” Later in its press release, CMS notes that the ONC will be soliciting feedback from across the industry in order to formulate this second set of certification standards. CMS notes that its 2015 standards will not be mandatory and that any vendors or providers that have chosen to go with a 2014 certified product will not be penalized or forced to adapt their systems. This approach has met mixed reviews from CIOs and Health IT execs who feel that creating two sets of standards in consecutive years will be cause for confusion and frustration, and will not have the desired effect of making for a smooth transition in 2017.

Finally, one benefit of the delay, perhaps unintended by CMS, is that it allows room for competing priorities in small and large systems in 2014. These include the ICD-10 deadline in October, meeting the much stricter HIPAA Omnibus rule (which is already in effect), the PQRS quality reporting system requirements, and the new accounting changes and accommodations needed to meet the increased patient load from ACA staged rollouts.

On the bright side, it does appear that CMS is being much more sensitive and responsive to the general concerns of providers, hospitals, and the healthcare IT industry as it moves forward. This shows that CMS has been able to reflect on and their approach and make essential changes after receiving so much criticism for its handling of Meaningful Use Stage 2.

About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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Nov
25
2013

This is the fourth installment of a five blog series on Prescription Drug Monitoring Programs (PDMPs) and the Electronic Prescribing of Controlled Substances (EPCS).

As the title suggests, one might ask which program is more important. Of course, as the reader may suspect, the answer depends on the perspective of each individual user.

PDMP Importance

Professionals working in fields such as public health, epidemiology and law enforcement are acutely aware of the accelerating epidemic of prescription drug abuse that has been growing across the United States for some time now (see my first blog in this series). The effects of this social problem have become so widespread that it has been affecting medical professionals in a wide range of other fields as well. Providers who work in behavioral health, addiction disorders, pain management, emergency departments, urgent care centers and even surgical specialists are all becoming, sadly, more familiar with the prescription drug abuse crisis.

The rising cost of this drug abuse crisis, as well as its accelerating pace, has made the issue of strengthening state PDMPs an important area of concern for many professionals in these circles. As a result, these programs are finally beginning to garner more attention. The benefits of utilizing PDMPs are relatively easy to summarize. When providers have access to accurate records regarding a patient’s prescription medication history they are more easily able to spot patterns of abuse and diversion of controlled substances and medications.

PDMPs eliminate the guess work for physicians who otherwise have to make intuitive decisions about a patient’s credibility in seeking powerful, highly regulated drugs. Judging by current national trends, this more empirical approach to handling prescriptions is important because leaving controlled substance distribution to the ‘gut level decisions’ of physicians has been a proven failure. Drug seekers and individuals who are seeking to abuse the system are quite often smart people, skilled manipulators, and, in many cases, highly innovative entrepreneurs with a strong motivation to deceive. Physicians need real information about a patient’s prescription history and drug consumption patterns in order to effectively counter this dynamic.

As mentioned in a recent blog, the state of New York has been a pioneer with its I-STOP legislation which mandates that medical providers consult PDMPs prior to writing any new prescriptions. Any medical provider in the state of New York who fails to comply with this mandate as of August 27, 2013, is liable to incur penalties including “fines, jail time and loss of licensure” according to a memorandum from the Medical Society of the State of New York.

New York’s I-STOP law is a major breakthrough for proponents of PDMP expansion for a number of reasons; the law effectively solves the problem of widespread non-participation through mandating that all physicians and practices actively consult the New York PDMP. In addition to this all important first step, the state of New York has also made an effort to adequately fund their PDMP to the extent that it always functions and functions well. These two developments effectively counter the largest obstacle which most state PDMPs are currently facing—a lack of willingness on behalf of providers to consistently utilize their local PDMP, as well as a lack of funding to make sure that PDMPs work well and are maintained effectively.

EPCS Importance

If the prescriber’s practice generates a high volume of controlled substance prescriptions it generally makes good sense to consider EPCS. This is particularly true if the clinician is already using electronic prescribing for legend drugs since EPCS eliminates the need to switch between these workflows, or to revert to paper or fax prescriptions.

With EPCS it is much easier to track and audit drug usage within an individual practice as well as a large group. This function is growing in importance as one of the management tools to help deal with the current crisis. In addition, prescribing controlled substances electronically also has the advantage of built-in clinical decision support in terms of drug-drug interactions, and drug dosage reminders, as well as other factors needed for reducing errors, enhancing patient safety, and improving overall treatment quality. The availability of modular, DEA compliant and certified EPCS applications that can interface with existing EHRs makes this solution more feasible and certainly faster to implement.

Which is More Important?

From the point of view of choosing which program is more important, clearly it depends on a number of factors including a risk analysis of the specific types and number of prescriptions, as well as the individual statutes in your area. It is clear that other states have recently addressed this issue with stricter regulations including reporting and tracking requirements that apply to prescribers, pharmacies, and, for some cases at the federal level, drug manufacturers. Probably the most effective single new tool in the armamentarium to help mitigate and manage the epidemic is the requirement for pharmacies to upload controlled substance dispensing information to the state PDMPs within 24 hours (or a very short timeframe following pickup of the prescription). Not all states have this narrow timeframe and many do not currently have the funds to support more sophisticated approaches to effectively monitor the problem and take action. Despite this fact, the regulations are becoming much more detailed and they require more action and accountability from providers and pharmacists.

My personal opinion is that both PDMPs and EPCS should be coupled in usage whenever and wherever possible. They are actually complementary. In selected cases, where a person is identified as someone who is clearly abusing opioids the first approach is to confront the patient with the evidence and offer specialized treatment as the best option. If addiction is clearly not the central issue, the physician must consider discharging the patient if appropriate. Of course, the duty to report abuse to authorities will vary by state so that each individual patient and their behavior must be addressed on a case-by-case basis.

DrFirst has been working with a few states over the past 18 months to pilot applications that improve office workflow, making it much easier to access highly secure PDMP databases from inside an e-prescribing application. These new features, being tested now, help reduce or eliminate the inefficiency of separate, time consuming PDMP logins and reduce the need to decide which system is more important.

My next and final blog on this topic will address differing prescriber roles and clinical workflow considerations.

***
UPDATE: As we are publishing this blog, the ONC has announced that it is convening a new series of webinars to promote standardization of PDMPs, thus reflecting their importance to the national fight against prescription drug abuse. (http://www.healthit.gov/buzz-blog/health-innovation/health-helping-fight-prescription-drug-abuse-epidemic/)

  1. The Controlled Substance Epidemic and Crisis
  2. PDMP – What is it?
  3. EPCS – What’s New?
  4. Which one is more important…PDMP versus EPCS?
  5. The Physician and prescriber role in Controlled Substance Fraud and Abuse
About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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Nov
11
2013

For the third blog in our series about the Controlled Substance Epidemic and Crisis, I’d like to talk about Electronic Prescribing of Controlled Substances (EPCS) and its importance in the healthcare market and the controlled substances epidemic.

Electronic Prescribing for Controlled Substances is a concept that has been discussed for many years although it was not until the Drug Enforcement Agency published the IFR (Interim Final Rule) in June 2010 that EPCS became legal at the federal level. Given the relative youth of e-prescribing of legend drugs, as well as the ingenious and troublesome ways in which fraud, abuse, and diversion have grown so widely, the DEA deliberated for approximately 10 years before issuing the IFR.

Since the mission of the DEA as part of the Department of Justice is primarily law enforcement, it’s no surprise that the medical management of addictive diseases, behavioral health, and pain as well as the complex coordination with providers and health plans, has taken a back seat in that agency over the past decade. However, the growing epidemic and crisis of prescription drug abuse, particularly the opioid and other psychoactive classes outlined in the first installment of this series has catalyzed action from all stakeholders.

In addition, similar to the situation with PDMPs–that each state has the authority to create and modify PDMP rules—EPCS is likewise subject to state variation with the proviso that the DEA’s strict requirements must be satisfied first. In other words, very much similar to HIPAA and other federal rules, the DEA IFR is a “floor” whereupon each individual state may build additional regulatory structures as it sees fit for its citizens and their environment. These state regulations usually are promulgated by the Department of Public Health, a Board of Pharmacy, or a combination of such statutory agencies.

Currently, only nine states do not permit EPCS but in several, legislation is pending and the status is unclear in a few states. Five states allow only Schedules III – V. The map s below illustrates this and it is changing from month to month.

EPCS States Schedule Map 2013.11.11 EPCS – What’s New?

New York is a special case due to the passage of the Internet System for Tracking Over-Prescribing Act (I-STOP) law passed in 2012, which mandates EPCS by March 27, 2015. I suspect other states will be considering this approach in the near future, depending on their own particular environment.

The single greatest benefit of EPCS to clinical prescribers is the ability to send all drugs electronically and have a single application that creates, manages, and stores every Rx, with detailed verification and safety checks at every step. Eliminating paper prescriptions entirely will also be a significant benefit for almost every stakeholder including pharmacists, drug companies, health plans, law enforcement agencies, and patients. However, EPCS places new responsibilities on EHR vendors, prescribers and pharmacies in terms of “Identity Proofing,” two factor authentication (e.g. using hard tokens such as those with one time passwords) and more robust audit trails as well as strict auditing procedures. In addition, to utilize Surescripts, the most widely accepted eRx network, there are other steps to their own certification. There are 14 vendors currently on the SureScripts EPCS certified list and DrFirst was the original member of this select group to actually send controlled substance scripts electronically.

Finally, despite the growing numbers of states passing EPCS enabling legislation, not all states have “turned on” their pharmacies, as this is a complex process involving both state regulatory agencies and individual as well as proprietary considerations with each and every pharmacy. The map below represents a recent status overview of the EPCS enabled Pharmacy distribution:

EPCS States Map 2013.11.11 EPCS – What’s New?

The next six to twelve months — looking ahead:

Since there are many competing priorities in healthcare clinical IT programs over the next year, e.g. managing costs, EHR adoption/upgrades, ICD-10 integration, ACO analytics, HIPAA/HITECH increased exposure and penalties, I suspect that EPCS rollouts will continue adoption at a slow to modest pace. The primary beneficiaries and thus early adopters are likely to be those who are high-volume controlled substance prescribers. These may include psychiatrists, pain management specialties, addiction specialists, oncologists, “end-of-life care” specialists, pediatricians who see large numbers of ADHD patients, selected surgeons who prescribe post-operative opioid analgesics and other physicians and “eligible prescribers” who must use controlled substances frequently to treat legitimate, relevant clinical disorders.

Their initial experience on how EPCS affects patient care and workflow will determine the speed of adoption among the remaining clinical community.

The next installment is: 4. Which one is more important…PDMP versus EPCS?

  1. The Controlled Substance Epidemic and Crisis
  2. PDMP – What is it?
  3. EPCS – What’s New?
  4. Which one is more important…PDMP versus EPCS?
  5. The Physician and prescriber role in Controlled Substance Fraud and Abuse
About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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Oct
11
2013

For the second blog in our series about the Controlled Substance Epidemic and Crisis, I’d like to talk about an abbreviation that soon will have growing impact on the practice of medicine and in particular the way we prescribe controlled substances to our patients.

PDMPs
PDMPs or Prescription Drug Monitoring Programs (sometimes shortened to PMP) were created by individual state legislation a number of years ago. They are tools for reducing prescription drug abuse and diversion. They consist of statewide electronic databases which collect, monitor, and analyze electronically transmitted prescribing and dispensing data submitted by pharmacies and dispensing practitioners. The data is used to support states’ efforts in education, research, enforcement and abuse prevention.

By 1989 only nine states had PDMPs though Hawaii started collecting data in 1943 (before it was a US state). All of these early PDMPs were coordinated with paper and/or faxes. The aggregated reports and, where relevant, PDMP investigations focused on prescribers selling prescriptions, pharmacies selling controlled substances illegally, and organized doctor shopping rings. The only focus at that time was Schedule II drugs. Since then, an Alliance of numerous states has been formed, the program has become electronic and the schedules expanded, though each state may still incorporate some variations. The DEA has no role in managing these state programs.

In 2010, Brandeis University received a grant through a division of the Department of Justice to fund a PMP Center of Excellence at the Heller School in order to provide practice-‐relevant information, evaluation, and expertise to PDMPs and their stakeholders, including the development of best practices. By June 2012, 49 states and one territory had passed PDMP legislation and 41 states had an operating PDMP.

Evidence that the PDMPs have been effective – if properly funded and the relevant data is timely – is building a strong case for the PDMPs to grow in importance. Although PDMPs currently differ in their relative emphasis on improving medical care versus reducing drug diversion and abuse, they are well positioned to serve both objectives.

Pressure to consult PDMPs before writing and dispensing controlled substance prescriptions is growing and in fact the State of New York passed the I-STOP law last year to mandate the use of their PDMP by August 27th, 2013 and EPCS by the end of 2014.

Other states are also modifying current law to make PDMPs more likely to be used, though in some states, funding the operations to make them effective and timely has been a major barrier. Problems with standardizing data formats and sharing information across state lines are among several challenges still facing efficient use of these programs. The National Association of Boards of Pharmacy (NABP) has recently created PMP InterConnect to facilitate sharing data across state borders to authorized users. This offers some promise of more efficient use of resources.

Pioneering in Michigan
According to the Bureau of Justice Assistance (BJA), registration rates for state PDMPs are exceedingly low, with the number of registered users typically ranging from 5% to 39% of potential authorized users within most states. This consistently low usage rate presents a major problem for states interested in curtailing the problems associated with rampant prescription drug abuse. The small percentage of healthcare providers that are currently using PDMPs also runs in stark contrast with the much larger percentage of healthcare providers that are currently using EHRs, EMRs, or e-prescribing solutions. The question for many lawmakers, public health experts, and medical decision makers that are concerned about this problem has subsequently become: How is it possible to get healthcare professionals to begin using PDMPs with the same regularity that they are using other healthcare IT solutions?

Last year, DrFirst participated in a pilot program with the State of Michigan to demonstrate the value of linking PDMP access within an e-prescribing application, in order to enhance efficiency and workflow. The results of the program were very promising, demonstrating a significant increase in the percentage of physicians who chose to consult the state’s PDMP prior to prescribing medication to their patients over the duration of the test.

In addition to greatly increasing the number of physicians who chose to consult the state PDMP during our pilot program, we were also able to demonstrate added clinical benefits that came from directly connecting our e-prescribing/EPCS module with the state’s PDMP. Our infrastructure is able to draw from more sources than the state’s PDMP, making the data which physicians received through the pilot program significantly richer and more clinically impactful than the data they would otherwise have been able to gather from merely consulting with the state’s PDMP.

Once the State of Michigan’s PDMP was supplemented with medication history data from our e-prescribing platform, physicians were also able to see controlled substance prescriptions written and filled outside of the State of Michigan. Physicians were also able to view an up-to-date list of the legend drugs that the patient was taking which was assembled through input from pharmacy fill data, payer information, and Surescripts—the national clearinghouse used by e-prescribing platforms to submit their prescriptions to pharmacies. These benefits demonstrate why other states ought to follow Michigan’s lead and begin experimenting with allowing e-prescribing/EPCS platforms to interface directly with state PDMPs.

  1. The Controlled Substance Epidemic and Crisis
  2. PDMP – What is it?
  3. EPCS – What’s New?
  4. Which one is more important…PDMP versus EPCS?
  5. The Physician and prescriber role in Controlled Substance Fraud and Abuse
About Tom Sullivan:

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

Find all posts by Tom Sullivan | Visit Website

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