PDMP & Health IT Integration All-Hands Meeting December 10th, 2013.

PDMP & Health IT Integration

All-Hands Meeting December 10th, 2013

Meeting Etiquette• Remember: If you are not speaking keep your

phone on mute• Do not put your phone on hold – if you need to

take a call, hang up and dial in again when finished with your other call– Hold = Elevator Music = very frustrated speakers and

participants

• This meeting, like all of our meeting is being recorded– Another reason to keep your phone on mute when not

speaking

• Feel free to use the “Chat” feature for questions, comments or any items you would like the moderator or participants to know.

NOTE: This meeting is being recorded and will be posted on the Meeting Artifacts Wiki page after

the meeting

From S&I Framework to Participants:Hi everyone: remember to keep your phone on mute

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Agenda

Topic Time Allotted

General Announcements 5 minutes

Review comment dispositions 45 minutes

Next Steps/Questions 10 Minutes

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General Announcements

• The PDMP & Health IT Integration All-Hands meets every Tuesday from 12:00-1:00 PM EDT– To participate please see the “Weekly Meetings” Section

of the PDMP & Health IT Integration Wiki Homepage:http://http://wiki.siframework.org/PDMP+%26+Health+IT+Integration+Homepage

Note: Please check the meeting schedule weekly to get the most up-to-date meeting information

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http://wiki.siframework.org/Data+Access+Framework+Homepage

http://wiki.siframework.org/Data+Access+Framework+Homepage

http://wiki.siframework.org/PDMP+&+Health+IT+Integration+Homepage


Join the Initiative • We encourage all

members to “sign up” or join the initiative. By joining this ensures you stay up-to-date with the work being done, communications and any initiative activities.

• Simply complete the Join Form on the Join Wiki Page: http://wiki.siframework.org/PDMP+%26+Health+IT+Integration+Join+the+Initiative

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http://wiki.siframework.org/PDMP+&+Health+IT+Integration+Join+the+Initiative




Phase Planned Activities Pre-Discovery Development of Initiative Background

Development of Initiative Charter Definition of Goals & Initiative Outcomes

Discovery Creation/Validation of Use Cases, User Stories & Functional Requirements Identification of interoperability gaps, barriers, obstacles and costs Review of Vocabulary

Implementation Creation of aligned specification Documentation of relevant specifications and reference implementations such as

guides, design documents, etc.. Validation of Vocabulary Development of testing tools and reference implementation tools

Pilot Validation of aligned specifications, testing tools, and reference implementation tools Revision of documentation and tools

Evaluation Measurement of initiative success against goals and outcomes Identification of best practices and lessons learned from pilots for wider scale

deployment Identification of hard and soft policy tools that could be considered for wider scale

deployments

S&I Framework Phases & PDMP & Health IT Integration Activities

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We are Here

Comments from wiki: Background…

Ben Loy PDX, Inc Committed Member

Background I agree with all four statements contained in the Background section. However, although this section states that "PDMPs are state-run electronic databases – functioning in 48 U.S. states and territories..." it does not state that these programs almost exclusively use one or more versions of the American Society for Automation in Pharmacy (ASAP) PMP Standard for collection of this data. This is important information as ASAP has worked to refine this standard over the past 18+ years to address information needs of these various state-run programs. Additionally, this information could impact decisions that the members may make regarding other processes that should be recommended.

Accepted with mod

We have included this as a potential standard and have included verbiage in the out of scope section with reporting from pharmacy to PDMP

Maria Friedman

Brookside Consulting Group

Committed Member

Background We should consider addressing the fact that there is a movement among states and stakeholders to make it mandatory for prescribers and pharmacists to check the PDMP database before a controlled substance is prescribed and dispensed. This underscores the need for interoperability for health IT systems in ambulatory and acute care settings with PDMPs.

Persuasive that is the point of this initiative . In some states prescribers are required to check the PDMP prior to dispensing controlled substances. This underscores the need for PDMPs to share information with health IT systems in ambulatory and acute care settings

Comments from wiki: Background

Douglas BlairPAST, Inc.

Other Interested Party Background

The third paragraph seems unnecessary. Since it is also only a single sentence, I suggest it be dropped. Perhaps finish the second paragraph with "However, PDMPs value as a diagnostic tool is severely hampered due to being "stand-alone" systems that are cumbersome and time consuming to access."

Accepted with Mod

Comments from wiki: EditsShelly Spiro

Pharmacy HIT Collaborative

Committed Member

Value Statement

Recommend changing the 3rd bullet to:The ability for prescribers, dispensers, and other medication management providers (e.g. pharmacists, care coordinators, behavioral health team members) to access prescription drug data for patients at the point of care to make informed decisions to reduce prescription drug misuse and overdose.

The reason to add "and other medication management providers (e.g. pharmacists, care coordinators, behavioral health team members). Providers that are not prescribing and dispensing should have access this information to make informed decisions to reduce prescription drug misuse prior to the prescribing and dispensing.

Accepted with modification - the description has been made more broad but within legal authorization

Edits

Rhonda May

OneHealthPort Committed Member

Challenge Statement

In additions to the lack of exchange between EHRs and PDMPs, there is also a lack of exchange between pharmacy systems and PDMPS.

Accepted with Mod changed EHR systems to include Health IT systems

Edits

Comments from wiki: GeneralRobert May II

IJIS Institute

Other Interested Party

General Comment

I believe the Charter is about right in the issues, challenges and risks it outlines and strongly support the purpose and goals.

Persuasive

Ben Loy PDX, Inc. Committed Member

Challenge Statement

I agree with the Challenge Statement to the extent presented. However, this statement does not recognize work that has already been provided by others in the industry to address the need of making the PDMP information collected by the state-run programs available to additional stakeholders in the broader healthcare environment. Specifically, the National Association of Boards of Pharmacy (NABP) has sponsored the “PMP InterConnect” initiative that currently provides access to the PDMP data collected by 21 of the state-run programs. This initiative uses state-of-the-art network and industry methods for providing this access that may provide a guide for the members. Additionally, ASAP has published an interface document that incorporates state-of-the-art network and industry methods that could also provide a guide for the resolution to the Challenge Statement.

Not persuasive As part of the Use Case development we will need to look at the work others have done. Additionally the winter concert series is a great way for those who are using HUBs to demonstrate what is being done.

Catherine Graeff

Sonora Advisory Group


General Comment

Looks good to me

Comments from wiki: Glossary/Terms

Maria Friedman


Committed Member

Scope Statement

Suggested addition:

Improving timely and convenient access to PDMP data by health care providers and pharmacists

Accepted with Mod

Health Care Providers to cover (pharmacists, prescribers, delegated authorities etc.) - this will be defined in the glossary

Maria Friedman


Committed Member

Stakeholders I'm wondering if health care organizations is too broad a statement for providers. To me, health care organizations has a feel of managed care, which is not the intent. We want to cover authorized prescribers (don't forget the PAs and nurses) in the range of ambulatory, inpatient, LTC and community health/mental health sites of care.

Accepted with Mod

added more details/examples to refine "health care organizations"

Rhonda May

OneHealthPort

Committed Member

Scope Statement

Need to find a terms that describes EHRs and Pharmacy systems and define it and use it consistently through the documentation as discussed in the meeting 11/26.

Accepted with Mod

Comments from wiki: Goals

Lynne Gilbertson

NCPDP Committed Member

Purpose and Goals

Suggested clarifications to item 2 and 5.1.Identify existing stakeholders and methodologies for accessing PDMP data.2.Identify, evaluate, and harmonize the data format(s) sent between EHRs/HIEs/pharmacy systems and PDMPs.3.Evaluate and select transport protocol(s) systems support.4.Evaluate and select security protocol(s) systems support.5.Map selected health IT standards to standards already in use for PDMP-to-PDMP interstate exchange. - Is in scope what (if anything) the PDMPs are sharing between themselves? Unclear. Or is this the ability for EHRs/HIEs/pharmacy systems to query PDMPs in another state? If yes, suggest to clarify 2 that it is in state and out of state.

Accepted with Mod

removed bullet 5 for reference

Comments from wiki: Risks…Maria Friedman


Committed Member

Potential Risks

I think the first bullet should be relabeled as privacy and security. There are a host of privacy concerns as well as security issues that are risks.

Accepted Added the label "Privacy and Security"

Eric Hilman MA EOHHS HIE


Scope Statement

Suggest that you include as in scope "discussion of the legal and policy (privacy mainly) implications" and "recommendation of legal (privacy) policies to support the envisioned technology"

One might imagine that some approaches that the group elects to support would require regulatory approval and my suggestion is to make that clear at the outset so that the PMP groups in the various states can decide whether to seek such approval and can have guidance as to exactly what the regulatory requirements are to implement any given technical capability

Accepted with Modification

Identified this as a risk: It is possible that some approaches presented in the Use Case may require state regulatory approval or modification

Comments from wiki: Risks

Rhonda May

OneHealthPort

Committed Member

Purpose and Goals

I wonder whether one of the goals should be to minimize the development efforts required for systems vendors to accommodate the standards chosen. The number of EHR and Pharmacy system vendors is quite large, relative to the number of PDMP vendors.

If this does become a goal, one value would be that there would likely be a quicker path to adoption.

Accepted with Mod We have added $ as a riskWhen we get to standards selection we can keep this s as one of the criteria when selecting standards (harmonization phase)

Lynne Gilbertson


Potential Risks

A potential risk is Incomplete information. This might occur because of different factors. 1) PDMP data that is reported may be available in a less than real-time basis which may compromise the most accurate information the provider system needs.2) PDMP data may be accessible on a state by state basis. Provider systems may have to check several surrounding states with multiple queries.

Accepted with mod How dated the information is out of the control of our work. --Included a risk titled "Incomplete information" It is a consideration the providers may have based on the time of query but our focus is on the queryPDMP to PDMP is out of scope

Comments from wiki: Scope…Charlie Oltman

Target Committed Member

Value Statement

Suggest changing last value statement to:

•The ability for prescribers and dispensers to access prescription drug data “real-time” at the point of care to make informed “clinical” decisions to reduce prescription drug misuse and overdose

Accepted with modification

the "real time" issue is out of scope and is somewhat loaded - maybe we could say the prescriber can access it at the point of care

Rhonda May

OneHealthPort

Committed Member

Scope Statement

Also, the goal should not be "connecting" PDMPs and health IT systems...the goal should be the exchange of information between them.

Accepted with Mod

Rhonda May

OneHealthPort

Committed Member

Scope Statement

Need to make the reporting of Rx dispenses to the PDMPs out of scope, based on my understanding of the discussion at the meeting 11/26.

Accepted with mod

Rhonda May

OneHealthPort

Committed Member

Scope Statement

In the State of WA implementation, the second phase of the PMP work planned is to have a query from a provider go to the "in state" PDMP on a patient with information in more than one state PDMP. The inter-state PDMP query and response exchange occur between the PDMP vendors and then the "in-state" PDMP vendor would send the response information back to the querying party. I am not entirely certain that PDMP - PDMP exchanges should be out of scope for this workgroup, and in fact it may limit the efficacy of the process and the ability to achieve the goals particularly along state borders where patients cross state lines.

Not persuasive

Comments from wiki: Scope…Rhonda May

OneHealthPort

Committed Member

Value Statement

The value statement needs to specifically call out something about integration of PDMP data into the provider/pharmacist normal workflow without requiring them to leave what they are doing to log into a different system or move to a different computer, etc..

Not persuasive Out of Scope- While we agree this is ideal we cannot mandate vendors incorporate it into their systems - this project focuses on using existing standards to query the PDMP - where this is done is not part of our scope

Lynne Gilbertson


Scope Statement

Suggest the scope help with the actual flow. Clarifications below:To allow system integrations that arms providers with PDMP data as part of their normal clinical workflow by:•Connecting health IT systems (e.g., EHRs, HIEs, pharmacy systems) to PDMPs using existing standards;•If standards do not exist, establishing standards for facilitating information exchange between health care providers and PDMPs to improve timely and convenient access to PDMP data by health care providers.

Accepted with Mod

Identify gaps in selected standards and work with standards organizations to fill in those gaps

Comments from wiki: Scope…Lynne Gilbertson


Scope Statement

Out of scope - suggest this bullet be discussed more. •Defining method for how the PDMP is contacted or initiated by provider (e.g., hyperlink while ordering, pressing a button, automatic trigger, etc..);

It does not seem out of scope to include the query (request) from the prescriber or pharmacy system to verify real-time against the PDMP database. It is out of scope that we would define hyperlink or pressing a button; agreed. However how the PDMP is initiated by provider is in scope (it is the query/request). Or am I misunderstanding the intent of the project?

Accepted We have included verbiage to discuss the difference between triggering event and the actual query. The actual transaction is in scope but how it is initiated or triggered is out of scope

Tia Johnson

DORA, CO Board of Pharmacy, PDMP


Purpose and Goals

I think that there should be some consideration / discussion in the Purpose and Goals Section which identifies if PDMP data is integrated into a health IT system, is it then saved within that Health IT System, and so once that integration occurs, does the PDMP data then become part of a medical record affiliated with that Health IT system? I am wondering if integration of data changes ownership of that data.

Not persuasive The integration will be left up to the healthIT system - during standards selection we should consider the ability of the standard selected to allow for integration. This is a consideration for system requirements when we get into developing the Use Case

Comments from wiki: ScopeDanna Droz National

Association of Boards of Pharmacy

Committed Member

General Comment

The purpose of this project is to identify standards to facilitate the delivery of prescription information from the PMPs to health care providers (prescribers and dispensers). Extraneous discussions such as how the state PMPs operate, how data is delivered TO the state PMP, how frequently the data is update, etc.. are out of scope, as noted in the charter. These discussions take time and focus away from the very specific task with specific goals and outcomes.

Persuasive We will continue to point to the out of scope statement as the group forms and works toward the S&I goals and deliverables

Douglas Blair PAST, Inc.


Scope Statement

Shouldn't the second bullet refer to "health IT systems," just like the first bullet, rather than "health care providers?"

Accepted

Comments from wiki: Stakeholders…Bill Lockwood ASAP Committed

MemberPotential Standards for Consideration

I also take issue with the fact that the PDMPs represented on the calls are not actively solicited for their opinions. Decisions made by this initiative directly impact these state-run programs. Therefore, the initiative “leader” has the responsibility, in my opinion, for asking what they think by polling them.So far many of the opinions that have been voiced are from pharmacy folks on the calls who have had no involvement with PDMPs over the years. I feel this has to be balanced out with input, as mentioned above, from PDMPs represented on the call. In a similar vein, in scrolling through the “committed members” I see companies that have had no involvement with prescription drug monitoring programs, yet can weigh in with a vote. This doesn’t seem appropriate to me. And there are far too many involved.

Under Consideration

This is an open initiative and everyone is allowed to join. We will monitor the engagement of all stakeholders to ensure to the extent possible there is as much broad participation as possible. We realize this was an issue with the previous PDMP work and are committed to making this more inclusive this go around.

Comments from wiki: Stakeholders…

Carl Flansbaum

NM PMP Committed Member

General Comment

I just want to second Bill Lockwood's comment. With well over 100 people on these calls with many members who do not seem to understand the specifics of how PMPs operate, it's frustrating to see how this initiative is exploding well beyond PDMP - Health IT System integration. I highly suggest those of us who are PMP Directors/Administrators (and the PMP hubs and PMP vendors) be more actively integrated into this process and we very quickly put anything beyond this narrow PDMP - Health IT System interchange out of scope.

Under Consideration


Douglas Blair

PAST, Inc.

Other Interested Party Stakeholders

I had suggested "Private Health IT companies" as a stakeholder on Tuesday. I am not referring to EHR/EMR companies, but rather third-party providers who utilize PDMP data. This is what my own company is, and we both interested in and affected by the outcome of this initiative.

Accepted

Comments from wiki: Stakeholders

Danna Droz

National Association of Boards of Pharmacy

Committed Member

General Comment

I am concerned about the amount of time available for comments, especially from the prescription monitoring program representatives. As we go forward, I'd like to see a concerted effort to include them in the discussions.Since these programs are operated by state governments, they are constrained in many ways that are not shared by private companies. In the last S&I Framework project with which I was involved, the prescription monitoring programs seemed to be dismissed as unimportant because "there are only 50 of them and there are hundreds of us". I hope this does not happen again.This supports previous comments by Bill Lockwood and Carl Flansbaum.

Under Consideration


Comments from wiki: Standards…Bill Lockwood

ASAP Committed Member

Potential Standards for Consideration

I take issue with the inclusion of the NCPDP Telecommunications Standard, which is used for billing claims, and the ASAP V4.2 PDMP reporting standard, which is used by every PDMP in the country, under the Potential Standards for Consideration. These have nothing to do with the Purpose and Goals of this initiative and to quote from this section: “The purpose of this initiative is to bring together the PDMP and health IT communities to standardize the data format and transport and security protocols to exchange patient controlled substance history information between PDMPs and health IT systems (i.e., EHRs/HIEs/pharmacy systems).” The purpose as defined has nothing to do with reporting from pharmacies, doctor dispensers, and veterinarians to PDMPs. The purpose is to bring into the workflow a more efficient means of accessing PDMP data on a person of interest. Therefore, I ask that these be deleted. The same holds true for the ASAP Zero Report standard. This standard is being used by pharmacies and others to report when no controlled substances were dispensed during a state’s reporting period. It has nothing to do with provider queries of a PDMP database.

Not persuasive These are potential standards and there is a chance during harmonization that these standards will fall off the list during harmonization. It is better to start broad and narrow the scope once we have a use case in place as the use case will drive the harmonization of standards

Comments from wiki: Standards…Ralph Orr VA PMP Other

Interested Party


Consider adding "REST" (maybe known as Restful) under Transport and Security Methods

Accepted Already listed as a standard

Lynne Gilbertson



NCPDP SCRIPT Standard is more than the transport - it is the transactions used in electronic prescribing including new prescriptions, changes to new prescriptions, renewal requests/responses, medication history, prior authorization transactions, fill status notifications, and other transactions.

Accepted

John Odden C4UH Committed Member


Typically, a PDMP Report is rendered as ISO 32000-1:2008 Portable Document Format. Some pharmacy boards issue electronic PDMP Reports in an extended format - PDF/Healthcare, a balloted best practice of AIIM and ASTM

Persuasive Added these to the standards list (content standards)

Comments from wiki: StandardsMichele Davidson

Walgreens Committed Member


I know it was discussed on the call, but the NCPDP Telecommunication Standard needs to be included under Other since we are looking at keeping this within the workflow of both prescribers and dispensers. Pharmacy systems use the NCPDP Telecommunication Standard as the standard to set up their pharmacy system and incorporating PDMP into this standard would enable pharmacists to see alerts within the prescription filling process.

Accepted Added to potential standards

Thomas Bizzaro

FDB (First Databank, Inc.)

Committed Member


If the goal is truly an integrated delivery of content to the PDMP the NCPDP Telecommunications standard should be included for consideration. The data elements required by the PDMPs from pharmacies will be found within this standard or should be added if necessary.

Accepted

Comments from wiki: StandardsMichele Davidson

Walgreens Committed Member


I know it was discussed on the call, but the NCPDP Telecommunication Standard needs to be included under Other since we are looking at keeping this within the workflow of both prescribers and dispensers. Pharmacy systems use the NCPDP Telecommunication Standard as the standard to set up their pharmacy system and incorporating PDMP into this standard would enable pharmacists to see alerts within the prescription filling process.

Accepted Added to potential standards

Thomas Bizzaro

FDB (First Databank, Inc.)

Committed Member


If the goal is truly an integrated delivery of content to the PDMP the NCPDP Telecommunications standard should be included for consideration. The data elements required by the PDMPs from pharmacies will be found within this standard or should be added if necessary.

Accepted

Comments from wiki: Typos

Ty OneHealthPort

Committed Member

Purpose and Goals

Typo..."though" was used when the correct word is "through"

Accepted with mod

Rhonda May

OneHealthPort

Committed Member

Scope Statement

typo - should read that "arm"...not that "arms". Accepted with mod We are focusing on the communications between PDMP and HealthIT system

Comments from wiki: Privacy/Security…

Adrian Gropper

Patient Privacy Rights

Committed Member

General Comment

I would add to the charter: PDMP is, by design, an involuntary citizen surveillance mechanism. PDMP with EHR interfaces must adhere to Fair Information Practice including data minimization, access minimization and transparency. Patient encounters that do not specifically involve controlled substances must not be impacted at all.

See line 49 (Deb Peel)

Deborah C. Peel, MD



General Comment

There should be major modifications to all sections of the document:

Proposed Project Charter:First the charter should note that PDMPs are law enforcement data bases, never intended to help patients and their physicians. This irony that this highly sensitive information is widely available to numerous state and federal government agencies and law enforcement, with thousands of employees authorized to access this very data and no oversight.

Deborah C. Peel, MD



General Comments Users' requests for data should also be subject to FIPs. Users should be

required to request the minimum data for a specific purpose and states should be able to add more patient privacy protections if they choose to (such as Oregon has done), since the Omnibus Privacy Rule made it clear that states can write laws that prevail over the HIPAA "floor" of data protections. FIPs see: http://epic.org/privacy/consumer/code_fair_info.html

Comments from wiki: Privacy/Security…Deborah C. Peel, MD



General Comments

Please eliminate the word "providers" and replace it with the licensed professionals who are treating the patients. Use the words "physicians and other health professionals licensed to treat patients" instead. Providers is a broad and misleading term that includes insurers and hospitals--institutions who do not actually treat patients or write prescriptions. Similarly , eliminate the word "prescribers' and use "physicians and other health professionals licensed to prescribe medications".

Deborah C. Peel, MD



General Comments

The charter should openly support the goals of requiring accountability and transparency from PDMPs so the public, whose data is collected, used, and disclosed in hidden ways can monitor the accuracy and use of this extremely sensitive personal information. The public should have "FIPs rights" to know and correct their data, have methods of recourse, etc.. And the Charter should openly support that all users of the data base be held accountable to those whose data they see via automatic electronic Accounting for Disclosures of all uses of their data in PDMPs.


Deborah C. Peel, MD



Challenge Statement

Please add: there is another way to ensure interoperability that this group should ALSO strongly endorse: patients should be able to obtain automated BB+ electronic copies of their prescriptions records from pharmacies for their own use and to disclose to physicians themselves. This again is critical for patient safety and ensures transparency and accountability.Today's' PDMPs provide no accountability or transparency. There is also no meaningful oversight or external auditing of the data bases. This groups should also recommend/support meaningful external oversight and auditing of data security and privacy. But above all patients must have the tools to audit and check things themselves, no one has a stronger interest in the accuracy or misuse of the data.

Deborah C. Peel, MD



Purpose and Goals

Before state-to-state interchange of data is mapped. the means of state to patient interchange should take place--that is the way the data can be used by those who need it for treatment! Those who need this data for treatment do not have it.It's critical that this project support and recommend getting this prescription data back into the patient's hands and back into the patient-physician relationship.


Deborah C. Peel, MD



Scope Statement

PDMP data should also be automatically available electronically to patients via BB+ and Direct secure email exchange. Again: intermediaries are not needed for data exchange as patients have the only clear rights to move PHI without any need for DURSA's etc..

Deborah C. Peel, MD



Out of Scope

The needs of patients to be able to delegate access to their own data in PDMPs should be in scope.

Deborah C. Peel, MD



Value Statement

There is no value in this statement for patients whose data this is! The outcome should include specification of interfaces so patients can get automated electronic copies of their prescriptions in PDMPs and exchange it themselves with their physicians or other licensed health professionals who treat them. There is NO NEED for access to this data base by dispensers. Surely that is an obvious law enforcement step. Dispensers are NOT the problem, the problems lie elsewhere (lack of access to effective treatment, treating health professionals and patients not having access to data for treatment, etc., etc.). Law enforcement intends to shut down pharmacies that they decide dispense too many controlled substances. Yet the problem is licensed health professionals prescribe these drugs for patients--the problems in that relationship are NOT addressed by allowing dispensers to deny prescriptions to patients. Dispensers are not at "the point of care" at all, they are not involved in care--nor do they have any legal authority to make treatment decisions or override decisions made by physicians and other health professionals licensed to prescribe controlled medications.


Deborah C. Peel, MD




These should include tools/standards for patients as detailed about to enable BB+ downloads of PDMP data via Direct secure email and to download Accounting for all Disclosures of PDMP data (names of users and purpose)--unless restricted by a court for investigation of crimes, etc..

Deborah C. Peel, MD



Potential Risks

Unintended access and patient mismatch can be best addressed by making PDMPs accountable and transparent to patients. Who cares more about those tow risks than the person whose data is at risk?There are huge risks that PDMPs will be subject to 'mission creep'---where all sorts of people will think of ways they could use that data. The data should only be used with informed, meaningful patient consent UNLESS a patient has been found to be breaking the law. Everyone else's data should not be accessible without court orders.

Deborah C. Peel, MD



Stakeholders Again, please change the vague and misleading terms as detailed above. The problem is that by naming all these groups as stakeholders, they appear to be designated as legitimate users/collectors/disclosers/sellers of this incredibly sensitive personal information. But they are NOT legitimate or legal users of this sensitive data that patients have strong rights to control and to prevent others from seeing and using. The only actual stakeholders are the patients and physicians (or other licensed health professionals). Those are the two parties involved in treatment. The rest should be called third parties or technology transport systems; some of which have clear legal rights or duties re:controlled substances data, but most don't.


Deborah C. Peel, MD



Stakeholders Exactly what data security and privacy protection laws do PDMPs fall under? It appears that they fall under HIPAA, which means that stronger state and federal laws, Constitutional rights to health information privacy, etc. apply. The only real 'stakeholders are patients and their designated representatives and the licensed health professionals they seek treatment from. As an expert psychiatrist, I have been following this issue for 37+ years in my practice. When sensitive prescription records are tracked by law enforcement, it decreases access to the medications: physicians are hesitant to prescribe and patients do NOT want to be spied on by law enforcement for their diseases, diagnosed and treated by licensed health professionalsThe ONLY people who should LOSE their rights to the privacy of records of their controlled substances prescriptions are those convicted of crimes. These data bases used the way this project intends violates the rights of everyone who takes a controlled substance. These people are all innocent of a crime until proven guilty. When law abiding citizens are openly surveilled simply because they take a medicine, this has an incredibly chilling effect on patients who genuinely NEED these very effective, worthwhile medications.

Comments from wiki: Privacy/Security

Deborah C. Peel, MD



Stakeholders correct it, or to have redress from harms. http://www.nytimes.com/2013/12/01/sunday-review/who-is-watching-the-watch-lists.html?partner=rss&emc=rss&_r=0 This group has an important opportunity to stop and think about the bigger picture, not just to technically connect PDMPs to EHRs. This group could be a force for fixing this terrible mess which violates the privacy of very sensitive information. BTW, since when has law enforcement stopped the War on Drugs? It’s about getting data, it’s not about not more policing/action to stop drug diversion and drug crimes, it certainly is not more treatment for addicts (treatment works very well BTW), and it destroys the privacy of millions of people who have committed NO CRIMES. This is another expansion of the War on Drugs and part of the IT industry's push to sell technology for everything (whether it really helps or not). Today as many as 1/3 Americans have "chronic pain"----do we really think 1/3 of Americans are criminals? The larger causes of this epidemic need to be identified before they can be fixed. PDMPs are not a solution, to the problem of drug abuse and drug related crimes. They should provide data ONLY to law enforcement with warrants and to patients, whose data it is. They are a source of information, but should NOT be accessible to health professionals without patients' informed consent. This data should certainly NOT be collected and disclosed or sold by EHR/EMR vendors, state HIEs/HIOs, health orgs, standards orgs, or payers (unless insurers paid for the prescriptions).

End to End Charter Review

1. Review the Final Project Charter– http://wiki.siframework.org/PD

MP+%26+Health+IT+Integration+Charter+and+Members

2. Fill out the comment form1. wiki.siframework.org/PDMP

+%26+Health+IT+Integration+Charter+and+Members#Comment

– All fields are required

3. Submit your comments

4. A Message is displayed verifying your comment was submitted

5. Once you receive the message your comment has been submitted you will be able to view your comment

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http://wiki.siframework.org/PDMP+&+Health+IT+Integration+Charter+and+Members



http://wiki.siframework.org/PDMP+&+Health+IT+Integration+Charter+and+Members#Comment




Next Steps

• Provide final comments on PDMP & Health IT Integration Charter

• Attend weekly “PDMP & Health IT All Hands Meetings” taking place every Tuesday from 12:00-1:00 PM EDT– Next Meeting December 17th, 2013

• Visit PDMP & Health IT Integration Wiki page – All Announcements, Meeting Schedules, Agendas, Minutes,

Reference Materials, Project Charter and General Data Access Framework information will be posted on the PDMP & Health IT Wiki page located at: http://wiki.siframework.org/PDMP+%26+Health+IT+Integration+Homepage

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NOTE: Please be sure to check the PDMP & Health IT Integration wiki homepage for the most up-to-date meeting information



Proposed Community Call Schedule

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Date Meeting Topics

Dec. 10th, 2013 • Review end to end comments• Begin Consensus process

Dec. 17th, 2013 • Review End-to-End Comment Review• Discuss Consensus process• Fall Concert Series – Target

Dec. 24th, 2013 • Meeting Canceled – Consensus will be announced

Dec. 31st, 2013 • Review Consensus comments• Achieve Consensus on Project charter

Initiative Support Leads

• For questions, please feel free to contact your support leads:

– Initiative Coordinator: Johnathan Coleman [email protected]– ONC Leads:

• Mera Choi [email protected]• Jennifer Frazier [email protected]• Scott Weinstein [email protected]

– SAMHSA Leads• Jinhee Lee [email protected]• Kate Tipping [email protected]

– Support Team:• Project Management:

– Jamie Parker [email protected]– Ali Khan [email protected] (Support)

• Use Case Development: – Presha Patel [email protected] – Ahsin Azim [email protected] (Support)

• Vocabulary and Terminology Subject Matter Expert: – Mark Roche [email protected] 37

mailto:[email protected]











Questions

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PDMP & Health IT IntegrationResources• Initiative Wiki Homepage

– http://wiki.siframework.org/PDMP+%26+Health+IT+Integration+Homepage

• Become a Community Member– http://wiki.siframework.org/PDMP+%26+Health+IT+Integratio

n+Join+the+Initiative• Project Charter

– http://wiki.siframework.org/PDMP+%26+Health+IT+Integration+Charter+and+Members

• Standards and Interoperability(S&I) Framework– http://wiki.siframework.org/Introduction+and+Overview

• S & I Calendar of Events– http://wiki.siframework.org/Calendar

39







http://wiki.siframework.org/Introduction+and+Overview

http://wiki.siframework.org/Introduction+and+Overview

http://wiki.siframework.org/Calendar

http://wiki.siframework.org/Calendar

PDMP & Health IT Integration All-Hands Meeting December 10th, 2013.

Documents

initiative http

initiative activities

integration wiki homepage

join wiki page

meeting artifacts wiki

mod slide

uptodate meeting information

meeting etiquette