DrFirst Response to The President’s Commission on Combating Drug Addiction and the Opioid Crisis Report

December 21, 2017

Tom Sullivan, M.D.

DrFirst Response to The President’s Commission on Combating Drug Addiction and the Opioid Crisis Report

DrFirst wholeheartedly supports efforts to combat the national opioid crisis.  While the focus on increasing awareness of this deadly epidemic is valuable, we must consider and address the underlying issues that have driven the situation to crisis proportions.  Without that, we run the risk, as we are starting to see now, of prescribers and the healthcare industry reacting to the opioid crisis by simply reducing opioid prescribing.  Limiting drug supply effectively pushes people with substance use disorder (SUD) to the streets in search of illegal opioids and other drugs.  Without a combined effort to prevent addiction while identifying and treating those who are addicted, we cannot solve this problem.  The clock is ticking and lives are lost daily.

DrFirst believes that technology can and should play a key role in the prevention of opioid abuse.  By using technology to close data visibility gaps, we can better arm physicians to identify patients at risk, as well as spot patients who are already suffering from addiction so they can find the appropriate treatment.

In our analysis of the Report issued by The President’s Commission on Combating Drug Addiction and the Opioid Crisis, we identified key areas where technology can drive meaningful change and improvement in combating the opioid crisis.  Our findings and recommendations are below.

PDMP:  Properly authorized, secured but easily accessible, Prescription Drug Monitoring Program (PDMP) data at the point of prescribing is a critical tool in helping prescribers acquire the information they need to support patient safety.  With a more accurate view of patient’s medications, prescribers can more readily spot individuals who are at risk for opioid addiction and engage in meaningful conversations face-to-face. This is the necessary precursor to prevent a true emergency and to initiate more intensive treatment.  To best support PDMP adoption, DrFirst believes that delivering PDMP data at the point of prescribing is key.  As such, PDMP data-sharing, and PDMP access for prescribers within the EHR or e-prescribing workflow, must play a major role in addressing the data visibility gaps that currently hamper prescribers’ ability to adequately support their patients.

The most effective and meaningful way to support delivering PDMP to physicians is to have a standardized protocol for PDMP data.  This need is critical and urgent.  Currently, PDMPs are managed at the state level, and each state has its own rules, process, data standards, and access protocols for the PDMP.  The result is that there is currently no simple way to connect all of these fragmented, incongruent data pools.  We must standardize protocols and streamline access to PDMP data to give prescribers meaningful, full patient medication histories.  Without it, physicians are prescribing blindly.

Electronic Prescribing of Controlled Substances:  E-prescribing has proven to be successful in decreasing drug diversion and fraudulent prescriptions.  Up to now, the adoption of EPCS, which has been legal in all US states since 2015, has been slow.  As the original vendor who worked with the DEA to help establish the current EPCS regulations, we believe that the current identity-proofing and onboarding process is hampering further adoption of EPCS.  A more simplified process that places less burden on physicians, while still providing the rigorous identity-proofing and authentication controls, is key to improving adoption of EPCS.

Prescribing Mandates:  Mandatory electronic prescribing of controlled substances (EPCS) and prescription drug monitoring programs (PDMP) has become the growing trend as states grapple with mounting opioid deaths. Eleven states have either mandated e-prescribing, or have pending legislation to require it in some form.  However, in order for the mandates to be effective, they must contain a balance of incentives, penalties, and waivers for special cases. As the first state to create and fully implement a mandate (2012-2016), New York appears initially to have achieved a reasonable mix.  In order for PDMPs and medication history tools to contain a patient’s true prescribing history, ALL prescriptions should be prescribed electronically. Not doing so thwarts productivity and masks the breadth, depth, and complexity of the current epidemic.

PDMP Reporting of Naloxone Administration:  The statistics are startling.  Approximately 10 percent of patients who have received naloxone to reverse an overdose die within one year, likely because the SUD remained untreated.  It is vital that prescribers have this information via their PDMP at the point of prescribing in order to provide life-saving guidance and treatment.

At DrFirst, for the past 18 years, we’ve been developing technology solutions to address patient safety problems in the medication prescribing and management area.   From our involvement in defining and executing the original EPCS pilot program with the DEA, HHS, and the State of Massachusetts in 2008, to our more recent work with state PDMPs and HIEs to bring PDMP data to prescribers within the e-prescribing workflow, we have become the national experts.  It’s our business, but it’s also our passion.  And we believe that by empowering prescribers through the use of technology, we give them the necessary tools to identify at-risk patients so that they can provide appropriate intervention early, helping to avoid addiction in the first place or treat it more effectively when necessary.

About Tom Sullivan, M.D.

Thomas E. Sullivan, M.D is a board-certified specialist in cardiology and internal medicine with over 40 years of clinical practice. He currently works for DrFirst and sees patients part-time in Massachusetts. His expertise in the application of information technology to health care has helped to create an international standard (ASTM) for the exchange of medical record information called the Continuity of Care Record (CCR). With AMA, he was founding chair of their e-Medicine Advisory Committee, worked with the Physician Consortium for Performance Improvement, represented the AMA and helped create the Physician EHR Coalition and is past chair of the AMA Council on Medical Service.