Report of the NABP PMP InterConnect Steering Committee September 25-26, 2012

Transcription

1 Report of the NABP PMP InterConnect Steering Committee September 25-26, 2012 Member States Present: Ralph Orr (VA), chair; Dean Wright (AZ); Teresa Anderson (ID); Craig Berberet (IL); Marty Allain (IN); Christina Morris (KS); Joe Casar (KY); Malcolm Broussard (LA); Michael Wissel (MI); Deborah Brown (MS); Larry Loring (NM), via phone; Mark Hardy (ND); Danna Droz (OH); Cheryl Anderson (SC); Randy Jones (SD); Marvin Sims (UT); and Cynthia Parsons (WV). Member States Absent: Connecticut and Delaware. Ex-Officio Members: Susan Martin (CO), via phone; Chedister Lane (IL); Barbara Carter (MN); Frank Gammill (MS); Lisa Adams (NV); William Bronson (NC); and Andrew Holt (TN). Others Present: Mark Conradi, Executive Committee liaison; Ron Hatfield, Jason Heath, and Clay Rogers, Appriss, Inc; Jim Huizenga, NARxCHECK, via phone; and Robert Cowan, Josh Bolin, Scotti Russell, Sally Stein, Lawana Lyons, Deborah Zak, and Lisa Huxhold, NABP. Introduction: The NABP PMP Interconnect Steering Committee met on September 25-26, 2012, at NABP Headquarters in Mount Prospect, IL. Committee Chairperson Ralph Orr welcomed attendees and took roll call. Agenda Approval and Announcements: The meeting agenda was introduced and a motion was made to approve the agenda. (Motion by Jones, seconded by Wright; unanimously approved.) NABP staff provided a brief overview of the meeting schedule for the next two days and reviewed the materials included in the meeting packet. Steering Committee Procedure: NABP staff explained that each state that has executed a memorandum of understanding (MOU) is invited to designate one representative to serve as a member on the PMP Steering Committee. In addition, ex officio members those who are in the process of signing on to NABP PMP InterConnect are invited to attend the meeting.

2 Staff also brought the committee up to speed on new processes and procedures, detailing the formalities now in place. Modeling committee procedures off of those formed for NABP committees and task forces, the Steering Committee will now have a designated Executive Committee liaison for each meeting. In addition, NABP staff explained the integration of confidentiality agreements into the meeting. As the prescription monitoring programs (PMPs) work to integrate PMP data into other projects and further enhance access to this data, some of the discussion and communications will be of proprietary nature. It was explained that some discussions will need to be covered under a confidentiality agreement. The committee will be informed when discussion will enter into an executive session. Review of Action Items, Motions, and Meeting Summary: The actions items, motions, and March 28-29, 2012 meeting summary were reviewed. A motion was made to approve the meeting summary. (Motion by Droz, seconded by Wright; 15 approved, three abstentions (T. Anderson, Jones, Parsons).) An update was provided on those states that have executed MOUs. NABP staff reviewed the NABP InterConnect fact sheet and map. PMIX Architecture Update: Compliance Update NABP staff provided a Prescription Drug Monitoring Information Exchange (PMIX) architecture update, explaining what was presented to Bureau of Justice Assistance (BJA) and Integrated Justice Information Systems (IJIS) Institute regarding interoperability issues stemming from three main items: (1) the fact that RxCheck implementation wraps PMIX XML requests in three additional tags; (2) PMIX uses digital signatures and NABP InterConnect does not; and (3) both hubs use key encapsulation with encryption; however, there are differences in how keys are derived and passed causing the hubs to be incompatible. The initial suggestions to BJA were developed by Appriss, Inc. Staff explained the four options presented to BJA with the focus on building compliance with PMIX architecture, while ensuring that the architecture meets the needs of the participants. Further discussion was tabled until after pilot update. Third Party Enhancing Access to NABP InterConnect Pilots With MITRE and Preliminary Results Wissel, Allain, Hardy, and Droz provided updates on their integration pilots. Wissel explained that Dr First was interested in expanding the pilot in Michigan as well as in other states. Allain shared results to date from the pilot with Indiana Scheduled Prescription Electronic Collection and Tracking (INSPECT) and Regenstrief, expressing the positive response received from emergency room doctors using the system. In addition, Hardy discussed the status of the North Dakota PMP pilot with an Indian Health

3 Service pharmacy and Droz provided an update on the integration of NARxCHECK into physician practice management. Overall the pilots received positive results. PMIX Architecture Update Revisited: The Steering Committee revisited the discussion on PMIX architecture after the pilot updates. NABP reviewed the four possible options moving forward in order to get PMIX and NABP InterConnect to be compatible. These options included: 1. NABP InterConnect adopts PMIX implementation. 2. NABP InterConnect and PMIX interoperate by changing encryption method. 3. Trusted Centralized PMIX-PMP InterConnect Intermediary. 4. Appriss creates a NABP InterConnect intermediary to be hosted at PMIX state. NABP staff also explained the responses from IJIS, which included a detailed revision to Option 1. Orr asked the Steering Committee for direction on what the committee views as viable option moving forward. Further discussion was tabled until the end of the committee meeting. Handling Third-Party Access Requests Authentication, Credentialing, and Accountability With the increase in requests from third parties, NABP is looking to the PMPs for guidance on the type of information the PMPs would like to obtain before considering allowing these third parties to connect. NABP staff posed two questions to the committee: (1) would the committee like NABP to facilitate these connections, and (2) if yes, what type of questions do the PMPs need answered? Droz explained that in Ohio, they talked with Walgreens to get PMP data integrated into the pharmacies and through the Substance Abuse and Mental Health Services Administration (SAMHSA) grant, and they have received a similar request from Kroger. Both entities wish to work through NABP to facilitate this connection. A motion was made for NABP to be the liaison/facilitator for third-party connections to the state PMPs and NABP InterConnect. (Motion by Droz, seconded by Allain; unanimously approved.) The committee agreed that the identity and role of the user would need to be authenticated. Allain shared that in Indiana, the contract the PMP holds with Regenstrief is very thorough and recommended that they use it as a resource when developing contracts with third parties. NABP staff also referenced a health information organization contract. The committee expressed the need to have a two-factor authentication process for electronic prescribing of controlled substances. Additional identifiers would be necessary for others. It was expressed that pharmacies authentication processes would differ from

4 chain to chain. Orr recommended that NABP research the Google Authenticator application. The committee also noted that there would need to be an audit trail to determine how long the third party plans to keep the data and if they would be providing the information to the states automatically or upon request. Some states require that data be provided on a regular basis. In addition, the states would need to know who queried the system and when, the parameters including the IP address, date and time of the query, and the patient who was queried. It was also stated that the data would need to be kept confidential and not subject to secondary use. A written agreement with the third party would need to be established and penalties for breach of the agreement would need to be developed. The committee agreed that all unauthorized use would need to be reported to NABP and the state PMP. The committee agreed that the following information would be necessary in order to consider a third party for connection to NABP InterConnect. Authentication of the identity and role of the user to ensure that the users are in fact authorized and utilizing the data for authorized use. Audit trail containing information on: o How long the data collected is kept and how often the data is provided to the state PMPs. o Parameters of the query including date range, IP address, data elements, search criteria, who requested the data, and who was queried. Assurance that the confidentiality of the data is maintained and not subject to secondary use. Mechanics and when in the workflow the request is triggered. How the data is presented. The data report must contain a disclaimer indicating that the report contains raw data and needs to be corroborated if used in cases for medical purposes. Evolving Care Models and Access to PMP Data Delving into a philosophical view, the committee discussed where they saw PMPs going in the future and what their role would be in the next three to five years. The members also discussed their thoughts on unsolicited reports. Several of the members agreed that they can be used as a marketing tool. Wissel explained that in Michigan, they saw a 50% reduction in the number of doctor shoppers since the state began automating the alerts. Wright shared that the Arizona PMP is now piloting a project where the PMP sends a report card to the top prescribers in each county. The report card tells the prescriber what they prescribed, how much was prescribed, and also gives them an average of what should be prescribed. During the pilot, which will take place for 12 to 18 months, prescribers will receive report cards on a quarterly basis.

5 Droz expressed her belief that eventually health information exchanges will want more data than what the PMPs have and that maybe they will need to consider including all prescription drugs in the data. Some states are in the process or have already passed laws to include all drugs. The committee also discussed the reporting trend as it moves more toward a daily reporting cycle. In some states, real-time reporting is required; however, the committee agreed that this can be pretty costly. Update/Discussion on Third-Party Proposals Upon a motion by C. Anderson, and seconded by Jones, the committee unanimously approved moving to an executive session. Following the update and discussion on third party proposals, the Committee moved to adjourn the executive session. (Motion by Hardy, seconded by Morris; unanimously approved.) SAMHSA Grants Illinois, West Virginia, Kansas, and Ohio provided brief updates on the SAMHSA grant status. Kansas explained that they are working to integrate health care with their software to create a flagging system. In Ohio, they are linking up with a hospital and with a group of physicians to integrate the process into the software. Other Efforts With Other Third Parties (HIE/NARxCHECK Integration) NABP staff explained efforts to look into additional ways to integrate NARxCHECK directly into the health care workflow through health information exchanges (HIEs). PMP Software Search Methodology Summary of SC/ND Pilot C. Anderson presented on the validity pilot, which was a result of a motion passed by the Steering Committee in March 2012, calling for the group to carry out a pilot on exchange of data in order to perform a validity measure. The pilot consisted of South Carolina, Ohio, and Michigan (South Carolina and North Dakota had tested previously) with a goal of querying each type of data system for the same query parameters and compare the findings. This included states with the same data vendor, states with different data vendors, and state supported systems. The findings from the interoperability validity testing demonstrated NABP InterConnect s ability to return valid results. C. Anderson encouraged the other state PMPs to begin connecting with their partner states through NABP InterConnect. Survey of Data Sharing The committee discussed the usability of the PMP InterConnect User Satisfaction Survey, developed by Orr as a direct result of an action item posed at the March 2012 meeting. The committee discussed the direction of the survey including how it should be distributed as well as what to do with the results. Morris recommended that the survey

6 results be both compiled and provided individually in order to assist with deciphering between vendors. It was recommended that NABP research survey tools including Survey Monkey. The committee also reviewed the suggested survey questions and revised as necessary. Orr called for a motion from the committee on the next steps for the survey development and distribution. A motion was made that NABP explore the options for creating a survey that states can use, hosted by NABP as opposed to individual state surveys. (Motion by Droz, seconded by Wright; unanimously approved.) PMP Software Certification Process Discussion Appriss provided an update on the PMP software certification process. Explaining that the process is still in development, the Appriss representatives asked for states to assist in testing of this process in order to ensure that the process works. In particular, states with internal IT staff were asked to participate. NARxCHECK Demo and NARxCHECK Insight NABP staff provided a presentation on NARxCHECK as well as samples of the reports provided through the software. Staff explained how the software accesses the information in the prescriptions dispensed database through the state PMPs and then subjects this information to an algorithm, computing a relative risk score for narcotics, sedatives, and stimulants. This three-digit score ranges from 000 to 999. Staff also provided an explanation of NARxCHECK Insight, which will leverage the NARxCHECK technology and scoring to assist in the evaluation of a large database of prescription data. The functionality of NARxCHECK Insight is complete and is now in the process of beta testing. Additionally, the NARxCHECK software is currently undergoing a validation process and will hopefully be introduced into the market by 1Q2013. Executive Summary The committee closed the September meeting with further discussion on PMIX architecture. The committee reviewed the history of the original hub to hub (PMIX-PMP InterConnect) expectations, BJA s involvement, and NABP s efforts to become PMIX compliant. The committee also addressed how changes in the architecture may or may not affect those state PMPs who are reliant on BJA s Harold Rogers Grant. The four compatibility options as described during the earlier PMIX architecture update discussion were reviewed and the committee moved to provide guidance on the future direction for NABP InterConnect as it relates to the PMIX architecture. The committee directs NABP to decline revised Option 1 due to the possible destruction or implosion of a working interconnected system. (Motion by C. Anderson, seconded by Wright; 17 approved, one opposed (Casar).) Committee directs NABP to decline Option 2 as it has too many unknowns, which are affected by cost, time frame, and effort. (Motion by C. Anderson, seconded by Hardy; 17 approved, one opposed (Casar).)

7 Committee directs NABP to submit Option 3 in the interest of time in order to continue interoperability as well as move forward with interconnectivity options with diverse health care entities. If Option 3 fails to be approved, the committee recommends Option 4 as an alternative. (Motion by C. Anderson, seconded by Wissel; unanimously approved.) If these options are not acceptable, the committee directs NABP to pursue other options (eg, changes in PMIX architecture or working with the Department of Health and Human Services) to develop interoperability standards. (Motion by C. Anderson, seconded by Hardy; 17 approved, one opposed (Casar).) The committee agreed to hold a follow-up conference call.