Providers have voiced opposition to a proposal aimed at targeting Medicare Part D enrollees with “potential opioid or acetaminophen overutilization issues that indicate the need to implement appropriate controls on these drugs for the identified beneficiaries.” Under a recently proposed rule on revised discharge planning requirements, CMS solicited comments on whether providers should be required to consult a patient’s history on their state’s Prescription Drug Monitoring Program (PDMP) in an effort to identify the patient’s risk of nonmedical use of controlled substances. PDMPs are state-run electronic databases that track prescribed and dispensed controlled prescription drugs to patients. According to CMS, “This information can help prescribers and pharmacists identify high-risk patients who would benefit from early interventions.”
Comments to the proposed rule show strong opposition by providers to the PDMP review requirement. Of principal concern are the many challenges associated with obtaining a reliable picture of a patient’s history from the PDMPs. For example, the American Medical Association commented that a review of a patient’s history on the PDMP may not portray an accurate or complete picture of the patient’s history, noting that patients who receive multiple controlled substance prescriptions from multiple pharmacies may reveal uncoordinated care, a patient who needs counseling or a referral for treatment, or a patient who has legitimately been issued those prescriptions. Many commenters also pointed to the logistical burdens of a PDMP review requirement, noting that PDMPs do not coordinate local, intrastate, or international tracking.
The potential for inefficiencies with the patient discharge process was another worry reflected by the comments. Of particular concern was the agency’s solicitation of public input on whether a PDMP review should be required for all patients “even if the practitioner is not going to prescribe a controlled substance.” Commenters cautioned that a blanket review requirement would overwhelm current patient discharge and transfer systems and distract from the focus on true high-risk groups. They also expressed concern that a PDMP review program would require a substantial investment to ensure the accuracy of patient history.
CMS has not said when a final rule on the revised discharge planning requirements might be expected. However, the input received by CMS in response to its solicitation of comments on the proposed PDMP review requirement indicates that more work and further vetting will be required. Time will tell whether CMS will heed the warnings and concerns expressed by the provider community on the many challenges associated with implementing PDMP review.