Tom Sullivan, M.D.

The Controlled Substance Epidemic and Crisis

Here we are toward the end of the summer of 2013, and not a day goes by that we don’t view or hear of some story in the local or national media that chronicles the usually tragic consequences of the widespread fraud, abuse, and diversion of controlled substances. Unlike in the past when we thought this concerned or involved only a small fraction of practicing doctors, most of these current stories are downstream effects of legitimate prescriptions written by hardworking, well intentioned and busy physicians.
In light of yesterday’s deadline for New York physicians to comply with I-STOP, the Internet System for Tracking Over Prescribing Act–and with over forty years of clinical practice as well as the past 20 years of involvement in clinical software design and implementation–I feel it’s a good time to share my observations about this topic. I believe that now is the moment to become more aware of the “rules and tools” that will help us and in some states will push us to aid the government’s effort to manage the problem.
Toward that end, this marks the first in a series of blogs about controlled substance e-prescribing, drug monitoring programs, and their impact on physicians and patients.
First, some background. On April 19, 2011, the White House released a comprehensive action plan, “Epidemic: Responding to America’s Prescription Drug Abuse Crisis,” to address the national prescription drug abuse epidemic.
Prior to that release, and since 2007, DrFirst has become a national leader in EPCS (Electronic Prescribing of Controlled Substances). Thanks to a federally funded 3-year pilot grant from The Agency for Healthcare Research and Quality (AHRQ) to the Department of Public Health in Massachusetts, DrFirst developed, tested, and implemented an electronic prescribing program for controlled substances in Western Massachusetts. This was done in strict compliance with the DEA rules at the time. DrFirst is the only company to have had this specific experience as a vendor of Health IT applications and services. In June 2010, the DEA publically promulgated its IFR (Interim Final Rule) making EPCS legal at the federal level and subject to each state’s additional laws and regulations over and above the IFR.
Starting out, one might want to ask the question “Why is this both a Crisis and an Epidemic?” Three graphics illustrate much of the recent history:



To address the national epidemic which has grown even more since the release of the data in the graphics above, the 2011 Prescription Drug Abuse Prevention Plan expands upon the Obama Administration’s National Drug Control Strategy and includes action in four major areas to reduce prescription drug abuse:

• Education. A crucial first step in tackling the problem of prescription drug abuse is to educate parents, youth, and patients about the dangers of abusing prescription drugs, while requiring prescribers to receive education on the appropriate and safe use, and proper storage and disposal of prescription drugs.
• Monitoring. Implement prescription drug monitoring programs (PDMPs) in every state to reduce “doctor shopping” and diversion, and enhance PDMPs to make sure they can share data across states and are used by healthcare providers.
• Proper Medication Disposal. Develop convenient and environmentally responsible prescription drug disposal programs to help decrease the supply of unused prescription drugs in the home.
• Enforcement. Provide law enforcement with the tools necessary to eliminate improper prescribing practices and stop pill mills.

In the next 5 installments I will address the issues below to expand on the epidemic and plans to reduce the severity of the problem:

1. The Controlled Substance Epidemic and Crisis
2. PDMP – What is it?
3. EPCS – What’s New?
4. Which one is more important…PDMP versus EPCS?
5. The Physician and prescriber role in Controlled Substance Fraud and Abuse