Before the Joint Committee on Public
Health
The Massachusetts Medical Society
supports efforts to improve the quality of data analysis done by the
Prescription Monitoring Program (PMP). We have supported the PMP since its
inception both philosophically and financially through fees on physicians and
other drug control program registrants. The MMS is strongly supportive of
efforts to work on improving educational opportunities for physicians and other
prescribers on opioid use. Last year the legislature mandated the creation of a
new task force to address opioid abuse. It hasn’t met yet. More needs to be done
to use the PMP and its extensive database effectively to identify problem
areas.
The MMS believes the PMP should focus on review of
its data to identify multiple prescriptions for the same patient whether from
multiple providers or a single individual. It needs to review the data it has
and do far more in outreach to physicians, pharmacists and the Board of
Registration in Medicine to investigate potential abusers whether patients or
providers. Pharmacists should have more data available from the PMP when they
dispense an opioid prescription to enable them to fulfill their responsibilities
in only filling legitimate prescriptions.
This legislation
is the latest in a string of legislative mandates including education on
opiates, participation in the PMP and broadening of the PMP database. The MMS
suggests this legislation could be improved by focusing on opioid abuse and
asking the PMP to review reported opioid overdose deaths and to cross reference
this material with PMP data. The MMS has suggested this approach before as a
source of clinical data to show what links there are between legitimate
prescribing and drug abuse which leads to death.
The MMS
has advocated that the research done by the PMP should be conducted with an
active clinical review group and statistically valid information about
individual prescribers should be shared with individual boards of registration
for review. The Board of Registration in Medicine has 100 staff. They have
clinical experts, investigators, attorneys and other professionals with the
resources to thoroughly review legitimate concerns about the quality of care an
individual physician provides.
The MMS has long argued
that the PMP and the Boards of Medicine, Nursing, Dentistry and other
disciplines should work together to identify trends and to identify individual
outliers whose prescribing is inconsistent with good quality
practice.
The PMP lacks the resources and staff to analyze
individual physician performance. The legislation calls for the PMP to do
exactly that and issue annual reports to the legislature on its findings. If
there are significant issues, they should be dealt with directly and in a timely
manner by the state agency responsible for protecting the public, the Board of
Registration in Medicine.
For these reasons, the MMS urges
the Committee on Public Health not to advance Senate 1029 as drafted.
