Massachusetts Prescription Monitoring Program PDMP Training and Technical Assistance Center at Brandeis University in partnership with the Bureau of Justice Assistance August 8, 2012 Massachusetts Department of Public Health Bureau of Health Care Safety and Quality Drug Control Program
MA PMP Unsolicited Reports Developed for Release to Law Enforcement-Regulatory Agencies N.B. The data from the PMP are only a part of the picture. Information is collected from pharmacies and subject to limitations.
Massachusetts Prescription Monitoring Program 1992 - MA PMP established by joint regulations with the Board of Registration in Pharmacy 1994 staff began presenting DCP developed cases to the Medical Review Group (MRG) for review and guidance on release.
Regulatory Authority 105 CMR 700.012 (4) (a) The Commissioner or a designee may disclose data collected pursuant to 105 CMR 700.012 to the parties enumerated in 105 CMR 700.012(D)(1)(c) through (f) in response to an inquiry or at the initiation of the Commissioner or designee. (b) Disclosure at the initiation of the Commissioner or designee shall be in conformance with any protocols established by the, in consultation with the Medical Review Group, concerning a patient, customer, practitioner or pharmacy potentially engaged in diversion or inappropriate dispensing. In providing such consultation concerning Department initiated disclosure, the Medical Review Group shall review the content and application of the protocols, make recommendations to the Department for effective use of such protocols and as needed review specific instances of Department initiated disclosure. In undertaking such review, the Medical Review Group shall be provided upon request with such pertinent information as needed.
Medical Review Group (MRG) Review the content and application of protocols and make recommendations to the Department for effective use of protocols to expedite release of cases. Review specific instances of Department initiated disclosure to make recommendations regarding release of cases.
DCP/ MA PMP Initiated Cases Review and analysis of data Patterns raise questions MRG recommendation for referral Law enforcement/reg agency
Massachusetts Prescription Monitoring Program Programs employed by PMP staff: Foxpro SQL Diver by Dimensional Insights
MA PMP Patient Information Fields PAT07 Last Name Required by MA PMP PAT08 First Name Required by MA PMP PAT09 Middle Name Required by MA PMP PAT10 Name Prefix Required by MA PMP PAT11 Name Suffix Required by MA PMP PAT12 Address Information 1 Required by MA PMP PAT13 Address Information 2 Required by MA PMP PAT14 City Address Required by MA PMP PAT15 State Address Required by MA PMP PAT16 Zip Code Address Required by MA PMP PAT17 Phone Number PAT18 Date of Birth Required by MA PMP PAT19 Gender Code Required by MA PMP PAT20 Species Code Required by MA PMP PAT21 Patient Location Code Required by MA PMP PAT22 Country of Non-U.S. Resident Required by MA PMP PAT23 Name of Animal
MA PMP Dispensing Information Fields DSP02 Prescription Number Required by MA PMP DSP03 Date Written Required by MA PMP DSP04 Refills Authorized Required by MA PMP DSP05 Date Filled Required by MA PMP DSP06 Refill Number Required by MA PMP DSP08 Product ID Required by MA PMP DSP09 Quantity Dispensed Required by MA PMP DSP10 Days Supply Required by MA PMP DSP12 Transmission Form of Rx Origin Code Required by MA PMP DSP16 DSP19 Classification Code for Payment Type Electronic Prescription Reference Number Required by MA PMP Required by MA PMP
MA PMP Customer Information Fields AIR03 Issuing Jurisdiction Required by MA PMP AIR04 AIR05 AIR06 ID Qualifier of Person Dropping Off or Picking Up Rx ID of Person Dropping Off or Picking Up Rx (Customer ID) Relationship of Person Dropping Off or Picking Up Rx Required by MA PMP Required by MA PMP Required by MA PMP
MA PMP Prescriber and Pharmacy Information Required by MA PMP Prescriber NPI when available DEA number Suffix when applicable Pharmacy NCPDP/NABP Provider ID DEA Number Pharmacy Name Pharmacy State Pharmacy Phone Number
Protocols for Unsolicited Reports Concerning Possible Criminal Activity Protocol Activity Type 95-01 Questionable Activity (Threshold Criteria) 99-01 Forgery (Algorithm)
DCP Release of Data by Protocol to DIU Dear Sergeant McQueeney, In a review of the MA Prescription Monitoring Program (PMP) data fourteen records of individuals, that presented as cases of possible questionable activity, were selected for release to the Diversion Investigative Unit. According to Protocol 95-01 regarding cases of suspected questionable activity by a customer the Department is releasing the data to Diversion Investigative Unit (DIU) for further investigation.
Indicators of Questionable Activity Single Customer/Patient Activity - Criteria for number of pharmacies, prescribers, period of time and total number of prescriptions - Supporting information e.g. time overlaps geography - prescriber and pharmacy long acting vs. short acting quantity per prescription
Indicators of Questionable Activity cont. Indicators: One customer ID w/ multiple patient names One patient name w/ multiple customer IDs One customer/ patient identifier: both M and F multiple dates of birth
Avoiding Detection One prescriber per pharmacy Fill dates would not look questionable to any one prescriber or pharmacy Drugs do not look questionable Dr. Smith is prescriber for Xanax and possibly small amount of oxycodone.
DCP Release of Data by Review to BRM Dear Mr. Beattie; In a review and analysis of information from the MA Department of Public Health s (Department) Prescription Monitoring Program (PMP), staff found patterns of prescription data which raised questions regarding the prescribing behavior of a registrant. The members of the Medical Review Group (MRG) reviewed the data and concurred that the records are indicators for possible medical practice issues. The Department and MRG agreed that the registrant s prescribing records for one year should be released to the Board of Registration in Medicine.
Practice Issues - Prescriber Prescriber compared to other prescribers number of prescriptions patients: number, gender, age types of controlled substances practice specialty (scope) geography Ds dated, duped, disabled, dishonest, defiant
Practice Issues - Prescriber Numbers of prescriptions or dosages units (Someone will always be #1)
Practice Issues - Prescriber Scope? Gynecologist prescribing stimulants for males Nurse Midwife prescribing Xanax for males Age Range Nurse Midwife 3 year olds? Pediatrician 41 year olds? Types of and quantities of controlled substances Typical family doctor vs. emergency room doctor
Practice Issues - Prescriber Five Ds Dated - Duped Dishonest Defiant Disabled Dated may be easier to determine because year of med school graduation is available from boards and other sources.
Additional Resources Folios - foliomed.com physician information includes addresses; phone, fax and emails; phone extensions medical specialties with board certification; medical school and year of graduation Boards of Registration Internet searches
MA PMP Developing Unsolicited Reports for Release to Law Enforcement / Regulatory Agencies Questions