Letter to Governor Patrick on Prescription Monitoring Program Regulations

March 14, 2013  

The Honorable Deval Patrick
Massachusetts State House
Office of the Governor
Room 280
Boston, MA 02133

Dear Governor Patrick,

The Massachusetts Medical Society (MMS) wishes to express our extreme concern with proposed regulations of the Department of Public Health on mandatory use of the prescription monitoring program (PMP).

Our primary concern is the regulations require all participants in the PMP, to log onto the prescription monitoring program and to review data on any patient who hasn't been seen in 12 months prior to a visit.  The regulations create exceptions to this mandate but the basic presumption is that every participant must check every patient.  Pediatricians must check 10 year olds needing a physical for little league.  Geriatricians must check an eighty year old presenting with flu symptoms.  The examples are limitless.

The MMS strongly supports the availability of an online system with accurate and timely information for use as a clinical tool by prescribers and dispensers.  Physicians are using the database now when their clinical judgment indicates that a patient may be seeking drugs for illicit purposes or demonstrating signs of abuse or addiction. It is a valuable tool when considering prescribing powerful narcotics to an unknown patient. It has no value whatsoever in the majority of clinical visits.

In 2011 the PMP found only 25 patients it felt exhibited behavior that resulted in alerts to prescribers.  This year, the DPH wants physicians, dentists and podiatrists to screen every new patient regardless of the clinical indications.  DPH staff has stated that the passage of Chapter 244 requires these reviews.  The MMS has pointed out numerous times that the legislature recognized the prescription monitoring program as a clinical tool with subtleties and required the DPH, in consultation with licensing boards,  to design a focused program to address opioid abuse.  The proposed regulations in no way fulfill this mandate.

The proposed regulations go well beyond the provisions of any other state's requirements and need to be redrafted.  We request your intervention to make the Prescription Monitoring Program an effective clinical tool.

 Sincerely,

/s/ Richard V. Aghababian, MD, FACEP
MMS President

 

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