AGENCY: 14-118 - Department of Health and Human Services (DHHS), Office of Substance Abuse and Mental Health Services (SAMHS)
CHAPTER NUMBER AND TITLE: Ch. 11, Rules Governing the Controlled Substances Prescription Monitoring Program: Section 5, Requirements for Dispensers
PROPOSED RULE NUMBER: 2013-P182
BRIEF SUMMARY: Change 14-118 CMR ch. 11, Rules Governing the Controlled Substances Prescription Monitoring Program: Section 5 Paragraph 2 Part D, Requirements for Dispensers: from “within seven (7) days of the controlled substance being dispensed”, to “within twenty four (24) hours of the controlled substance being dispensed”.
DETAILED SUMMARY:
Rationale: More timely data are expected to enable more informed prescribing and improved detection of questionable activity.
Evidence of effectiveness: Briefing on PDMP Effectiveness - http://www.pdmpexcellence.org/sites/all/pdfs/briefing_PDMP_effectiveness_april_2013.pdf .
Current adoption status: States vary in data collection interval, most at one or two weeks; one state has implemented real-time data collection.
Barriers to adoption: Cost, staff time, information technology hurdles.
A detailed report follows:
B. Reduce data collection interval; move toward real-time data collection
Rationale and evidence of effectiveness: State PDMPs receive updated prescription dispensing data from pharmacies at varying intervals, ranging from monthly to daily, with most pharmacies reporting every one or two weeks (ASPMP state profiles, 2011). This means that even PDMPs that supply end users with immediately available online reports are delivering data that often do not include patients' most recent prescription purchases. These omissions compromise the utility of prescription history data for clinical practice and drug diversion investigations (PDMP COE, NFF 2.3).
The Alliance of States with Prescription Monitoring Programs' PMP Model Act 2010 Revision recommends that pharmacies submit prescription data "no more than seven days from the date each prescription was dispensed" (ASPMP, 2010). Ideally, PDMP data would be collected in real-time, within a few minutes of a drug being dispensed. PDMPs across the country report increased demands from prescribers, particularly emergency department physicians, for prescription histories of their patients that are complete at the time of seeing a patient. The Oklahoma PDMP has implemented real