The Massachusetts
Medical Society (MMS) wishes to be recorded in support of the House bill 3486
and Senate bill 1277, An Act Relative to the Prescription Monitoring Program.
The
Massachusetts prescription monitoring program, known as MassPAT, is relied upon
by prescribers across the state as an accurate list of all controlled substance
prescriptions dispensed at outpatient pharmacies in Massachusetts. It is a
critical tool for physicians to understand what prescriptions are being taken
by their patients. Unfortunately, there is an important gap in the data
uploaded into the MassPAT: it does not contain methadone dispensed for the
treatment of opioid use disorder. Methadone is required by federal law to be
dispensed by medical order at certified opioid treatment programs (OTPs),
rather than by prescription at outpatient pharmacies. This bill would amend the
prescription monitoring program statute to allow opioid treatment programs to
submit prescription information for methadone used to treat opioid use disorder.
Many
physicians have noted that the absence of methadone information in the
prescription monitoring program poses significant patient safety concerns.
Users of the PMP believe they are seeing a complete list of controlled
substances taken by a patient, and the lack of methadone information is a
glaring omission. Methadone prescribed for treatment of pain is included in the
prescription monitoring program, as is buprenorphine, another medically
assisted treatment used to treat opioid use disorder.
The
primary barrier that has precluded OTPs from reporting data regarding methadone
usage is a federal privacy law, 42 CFR Part II. H/3486.S.1277 acknowledges the
challenges placed by the federal privacy laws and encourages pathways toward
reporting of methadone that do not conflict with federal law. Notably, the
federal government in a current rulemaking has proposed a set of changes to 42
CFR Part II that would allow OTPs to enroll in state prescription drug
monitoring programs and submit the dispensing data for controlled substances
with patient consent, and consistent with state law. We believe this law
would provide clear intent to OTPs that if federal privacy laws and regulations
are changed, there is clear intent by the state to encourage reporting. We therefore
encourage favorable reporting of this bill.
