Prescription Drug Monitoring Program Issues

Comments:

Attached some of my concerns regarding the rules governing the Prescription Drug Program:

* "3) All dispensers will electronically report data to the Program's database not more than 15 days after the controlled substance has been dispensed.."
o Result: Organized drug purchasers and traffickers will go from clinic to clinic to buy drugs within the 15-days period and those clinics will delay reporting to the legal limit to allow their "clients" to purchase drugs because that's were the money comes from. These are the facts on the ground. How can we stop that? By lobbying for a reporting requirement within 24-hour time period. Every time I create an electronic prescription during a routine patient interaction in the exam room the prescription data is automatically being submitted to the e-prescribing database. E-prescribing software vendors (such as Allscripts) should upload all controlled substances directly to the monitoring program.
* "4) Data not accepted by the database system due to a substantial number of errors or omissions shall be corrected and resubmitted to the database by the reporting dispenser within five days of receiving written notice that the submitted data was unacceptable."
o Result: Crafty and clever dispensers may intentionally submit incorrect data, await the written notice and then resubmit the data after five days. Meanwhile, they can continue to serve the commercial drug dealers. Whats the penalty mechanism? How many times can they submit incorrect data without being fined?

Furthermore, one of my colleagues pointed out that the rules do not provide for fines, penalties, license suspension/revocation, or anything else for offenders, and especially for repeat offenders. The item above is limited to "failing to report", but does not cover purposeful misbehavior as described in my comments.
The way this is written,it allows dutiful physicians to look up and see if their patient is trying to scam them. It does NOT provide the department or law enforcement very easy tools to find and prosecute "pill mills", who are actually the real public health problem.

I am looking forward to your comments.
Yours

Bernd