report for nascsa pmp survey 2019 pmp survey 2019.pdf · veterinarians to access the pmp 14% f....
TRANSCRIPT
Report for NASCSA PMP Survey 2019
C o mpletio n Ra te: 8 0 %
Complete 24
Partial 6
T o ta ls : 30
Response Counts
1. Which PMP state or jurisdiction are you responding om behalf of?
4% Alabama4% Alabama
4% Alaska4% Alaska
4% Arkansas4% Arkansas
4% Colorado4% Colorado
4% Connecticut4% Connecticut
4% Delaware4% Delaware
4% Guam4% Guam
11% Hawaii11% Hawaii
4% Idaho4% Idaho
4% Kentucky4% Kentucky
4% Maryland4% Maryland
4% Michigan4% Michigan4% Missouri4% Missouri
4% Nebraska4% Nebraska
4% Nevada4% Nevada
4% New Jersey4% New Jersey
7% North Dakota7% North Dakota
4% Oklahoma4% Oklahoma
4% Oregon4% Oregon
4% Pennsylvania4% Pennsylvania
4% Puerto Rico4% Puerto Rico
4% Rhode Island4% Rhode Island
4% Texas4% Texas
4% Vermont4% Vermont
Value Percent Responses
Alabama 3.7% 1
Alaska 3.7% 1
Arkansas 3.7% 1
Colorado 3.7% 1
Connecticut 3.7% 1
Delaware 3.7% 1
Guam 3.7% 1
Hawaii 11.1% 3
Idaho 3.7% 1
Kentucky 3.7% 1
Maryland 3.7% 1
Michig an 3.7% 1
T o ta ls : 27
Missouri 3.7% 1
Nebraska 3.7% 1
Nevada 3.7% 1
New Jersey 3.7% 1
North Dakota 7.4% 2
Oklahoma 3.7% 1
Oreg on 3.7% 1
Pennsylvania 3.7% 1
Puerto Rico 3.7% 1
Rhode Island 3.7% 1
T exas 3.7% 1
Vermont 3.7% 1
T o ta ls : 27
Value Percent Responses
2. Veterinary - Related Questions2. When prescriptions for animals are dispensedand reported by a retail pharmacy, which ASAP fields are required to be reported toyour PMP? Select all that apply.
Per
cent
a. PAT07 –
Last
Name
b. PAT08 –
Owner’s
Firs
t Name
c. PAT08 –
Anim
al’s F
irst N
ame
d. PAT18 –
Owner’s
Date
of B
irth
e. PAT18 –
Anim
al’s D
ate o
f Birth
f. PAT19 –
Owner’s
Gender
g. PAT19 –
Anim
al’s G
ender
h. PAT20 –
Specie
s Code
i. PAT23 –
Name o
f Anim
al
j. We d
o not o
ffer g
uidance o
n the re
porting o
f anim
al pre
scrip
tions
k. Oth
er - P
lease S
pecify (
text
box)0
50
25
75
Value Percent Responses
a. PAT 0 7 – Last Name 53.6% 15
b. PAT 0 8 – Owner’s First Name 32.1% 9
c. PAT 0 8 – Animal’s First Name 25.0 % 7
d. PAT 18 – Owner’s Date of Birth 35.7% 10
e. PAT 18 – Animal’s Date of Birth 21.4% 6
f. PAT 19 – Owner’s Gender 25.0 % 7
g . PAT 19 – Animal’s Gender 28.6% 8
h. PAT 20 – Species Code 32.1% 9
i. PAT 23 – Name of Animal 17.9% 5
j. We do not offer g uidance on the reporting of animal prescriptions 42.9% 12
k. Other - Please Specify (text box) 25.0 % 7
k. Other - Please Specify (text box) Count
Oreg on does not collect animal rx 1
PAT 20 and PAT 23 are Situational, not Required 1
Reporting of animal prescriptions is not required 1
T he Alaska Board of Veterinary Examiners has not yet established further g uidelines for how to
report.
1
Vets are not required to submit data, only pharmacies that dispense animal medications.
However we will take data should it be submitted by a vet and are in the process to provide
g uidance that requires Pat0 7, 0 8 Owner, 0 18, 20 , and 23. T here is a process which is under
discussion.
1
Vets are not required to submit data, only pharmacies that dispense animal medications.
However we will take data should it be submitted, by a vet and are in the process to provide
g uidance that requires Pat0 7, 0 8 Owner, 0 18, 20 , and 23. T here is a process which is under
discussion.
1
mostly our retail report under the owner with the species code. 1
T otals 7
3. 3. Do dispensing veterinarians report to your PMP?
30% a. Yes30% a. Yes
70% b. No70% b. No
Value Percent Responses
a. Yes 30 .0 % 9
b. No 70 .0 % 21
T o ta ls : 30
4. Veterinary-Related Questions4. When prescriptions for animals are dispensedand reported by a dispensing veterinarian, which ASAP fields are required to bereported to your PMP? Select all that apply.
Per
cent
a. PAT07 –
Last
Name
b. PAT08 –
Owner’s
Firs
t Name
c. PAT08 –
Anim
al’s F
irst N
ame
d. PAT18 –
Owner’s
Date
of B
irth
e. PAT18 –
Anim
al’s D
ate o
f Birth
f. PAT19 –
Owner’s
Gender
g. PAT19 –
Anim
al’s G
ender
h. PAT20 –
Specie
s Code
i. PAT23 –
Name o
f Anim
al
k. Oth
er - P
lease S
pecify (
text
box)0
100
25
50
75
Value Percent Responses
a. PAT 0 7 – Last Name 88.9% 8
b. PAT 0 8 – Owner’s First Name 55.6% 5
c. PAT 0 8 – Animal’s First Name 33.3% 3
d. PAT 18 – Owner’s Date of Birth 55.6% 5
e. PAT 18 – Animal’s Date of Birth 33.3% 3
f. PAT 19 – Owner’s Gender 11.1% 1
g . PAT 19 – Animal’s Gender 66.7% 6
h. PAT 20 – Species Code 77.8% 7
i. PAT 23 – Name of Animal 55.6% 5
k. Other - Please Specify (text box) 33.3% 3
k. Other - Please Specify (text box) Count
In the middle initial field (PAT 0 9) we ask that they identify the type of animal "dog /cat/g oat" etc.
for assistance when dealing with pet stores, shelters, or a zoo.
1
PAT 20 and PAT 23 are Situational, not Required 1
T he Alaska Board of Veterinary Examiners has not yet established further g uidelines for how to
report.
1
T otals 3
5. Veterinary-Related Questions5. Are the ASAP reporting specifications for animalprescriptions the same whether the data is submitted by a retail pharmacy or adispensing veterinarian?
32% a. Yes32% a. Yes
7% b. No7% b. No
61% c. n/a61% c. n/a
Value Percent Responses
a. Yes 32.1% 9
b. No 7.1% 2
c. n/a 60 .7% 17
T o ta ls : 28
6. 6. When a prescription is dispensed to an animal, is the dispensation associatedwith the owner’s PMP report in anyway? Please select the most appropriateresponse.
46% a. Yes - If owner's name isqueried, the animal Rx willappear
46% a. Yes - If owner's name isqueried, the animal Rx willappear
21% b. No - If the owner's name isqueried, the animal Rx will notappear
21% b. No - If the owner's name isqueried, the animal Rx will notappear
32% c. Other - Please Explain(text box)32% c. Other - Please Explain(text box)
Value Percent Responses
a. Yes - If owner's name is queried, the animal Rx will appear 46.4% 13
b. No - If the owner's name is queried, the animal Rx will not appear 21.4% 6
c. Other - Please Explain (text box) 32.1% 9
T o ta ls : 28
c. Other - Please Explain (text box) Count
It depends whether the MPI links the records tog ether or not. 1
N/A 1
Not required to report 1
Only if the pharmacy has reported the prescription with owner's information. 1
Oreg on does not collect animal Rx in the PMP 1
T here's no identifier linking the animal's owner to the animal. 1
We are in process of standardizing reporting and search. 1
it would depend on how the information was reported 1
n/a 1
T otals 9
7. 7. If your state allows veterinarians to query the PMP, who are they allowed tosearch?
14% a. The owner (and they willsee both the owner and animal’sdata)
14% a. The owner (and they willsee both the owner and animal’sdata)
18% c. The animal18% c. The animal
21% d. Both the owner and theanimal21% d. Both the owner and theanimal
32% e. My state does not allowveterinarians to access the PMP32% e. My state does not allowveterinarians to access the PMP
14% f. Other - Please Explain(text box)14% f. Other - Please Explain(text box)
Value Percent Responses
a. T he owner (and they will see both the owner and animal’s data) 14.3% 4
c. T he animal 17.9% 5
d. Both the owner and the animal 21.4% 6
e. My state does not allow veterinarians to access the PMP 32.1% 9
f. Other - Please Explain (text box) 14.3% 4
T o ta ls : 28
f . Other - Please Explain (text box) Count
Can query the owner if they suspect drug abuse or animal mistreatment, otherwise can only
query animal
1
N/A 1
Veterinarians do not have direct access and requests are processed by paper requests. T hese
are handled on an individual basis and are reviewed by the Executive Director's and provided
at their discretion depending on the finding s of the report. We've had 2 or 3 requests in 12
years.
1
they are not required to use 1
T otals 4
8. 8. T o what extent do you agree that a solution such as this would be beneficialto your state: If a veterinarian’s role was restricted so that upon querying the owner,only the animal’s prescriptions would appear, this would be beneficial to the state’sPMP.
33% a. Strongly agree33% a. Strongly agree
15% b. Agree15% b. Agree26% c. Neither agree nordisagree26% c. Neither agree nordisagree
15% d. Disagree15% d. Disagree
11% e. Strongly disagree11% e. Strongly disagree
Value Percent Responses
a. Strong ly ag ree 33.3% 9
b. Ag ree 14.8% 4
c. Neither ag ree nor disag ree 25.9% 7
d. Disag ree 14.8% 4
e. Strong ly disag ree 11.1% 3
T o ta ls : 27
9. Out of State Law Enforcement 9. Does your Prescription Monitoring Programallow requests for patient reports, prescriber reports, or dispenser reports from outof state law enforcement
64% a. Yes64% a. Yes
36% b. No36% b. No
Value Percent Responses
a. Yes 64.3% 18
b. No 35.7% 10
T o ta ls : 28
Yes No N/A Responses
a. Release pa tient repo rts to out of state law enforcement?
Count
Row %
15
88.2%
0
0 .0 %
2
11.8%
17
b. Release pres criber repo rts to out of state law
enforcement?
Count
Row %
14
82.4%
1
5.9%
2
11.8%
17
c. Release dis pens er repo rts to out of state law
enforcement?
Count
Row %
14
82.4%
1
5.9%
2
11.8%
17
d. Release a udit tra il info rma tio n to out of state law
enforcement (Audit trail information is a record of patient
searches performed by an account holder in the PMP)?
Count
Row %
10
58.8%
3
17.6%
4
23.5%
17
e. Require a subpoena in order to release data to out of state
law enforcement?
Count
Row %
6
35.3%
9
52.9%
2
11.8%
17
f. Require a search warrant in order to release data to out of
state law enforcement?
Count
Row %
2
12.5%
11
68.8%
3
18.8%
16
g . Require an application for out of state law enforcement?
Count
Row %
6
37.5%
7
43.8%
3
18.8%
16
h. Require there be an open-investig ation prior to releasing
data to out of state law enforcement.
Count
Row %
11
64.7%
2
11.8%
4
23.5%
17
i. Have an application for out of state law enforcement
available on the PMP website?
Count
Row %
6
37.5%
6
37.5%
4
25.0 %
16
10. Out of State Law Enforcement10. Does your PMP…
j. Require additional information prior to releasing data to out
of state law enforcement? (If Yes - please explain in the text
box below)
Count
Row %
12
70 .6%
5
29.4%
0
0 .0 %
17
T otals
T otal Responses 17
Yes No N/A Responses
ResponseID Response
3 Case number must be provided
4 Case number must be provided
7 Case number, type, and descriptionf. Must be notarized if submitted using a form.
Deceased patients require a subpoena.
8 We would only allow online access to out of state Federal law enforcement.
9 Case or file number
15 Law Enforcement or a Reg ulatory Ag ency is required to submit a formal request on
letterhead, summarizing the existing investig ation, the need and scope of information
requested. Federal, State, or County Law enforcement officers, investig ative ag ents of
federal, state, or county law enforcement or reg ulatory ag encies, United States
attorneys, county prosecuting attorneys, or the attorney g eneral; provided that the
Controlled Substance Administrator has reasonable g rounds to believe that the
disclosure of any information collected under this part is in furtherance of an ong oing
criminal or reg ulatory investig ation or prosecution
16 Law Enforcement or a Reg ulatory Ag ency is required to submit a formal request on
letterhead, summarizing the existing investig ation, the need and scope of information
requested. Federal, State, or County Law enforcement officers, investig ative ag ents of
federal, state, or county law enforcement or reg ulatory ag encies, United States
attorneys, county prosecuting attorneys, or the attorney g eneral; provided that the
Controlled Substance Administrator has reasonable g rounds to believe that the
disclosure of any information collected under this part is in furtherance of an ong oing
criminal or reg ulatory investig ation or prosecution;
21 for non-DEA out-of-state law enforcement, we g enerally receive warrants and each law
enforcement request is reviewed by Leg al Affairs before responding
23 In addition to a subpoean, a certification of the request must also be submitted.
25 Require subpoena issued pursuant to court order for all law enforcement requests
26 they are requried to make the request throug ht the appropriate ag ency in our state then
it is sent to the PMP. ie . licensure boards, bureua of narcotics - required to have open
investig ation and case nubmer
29 Information can be released to law enforcement with a valid subpoena, warrant, or court
order
11. If you answered Yes to question (j) please include your explanation in thefollowing text box:
12. Out of State Regulatory Officials 11. Does your Prescription MonitoringProgram allow requests for patient reports, prescriber reports, or dispenserreports from out of state regulatory officials (Boards of Pharmacy, Medical Board,Nursing Board)
46% a. Yes46% a. Yes
54% b. No54% b. No
Value Percent Responses
a. Yes 46.4% 13
b. No 53.6% 15
T o ta ls : 28
Yes No N/A Responses
a. Release pa tient repo rts to out of state reg ulatory officials?
Count
Row %
7
63.6%
1
9.1%
3
27.3%
11
b. Release pres criber repo rts to out of state reg ulatory
officials?
Count
Row %
9
81.8%
0
0 .0 %
2
18.2%
11
c. Release dis pens er repo rts to out of state reg ulatory
officials?
Count
Row %
8
72.7%
0
0 .0 %
3
27.3%
11
d. Release a udit tra il info rma tio n to out of state reg ulatory
officials (Audit trail information is a record of patient searches
performed by an account holder in the PMP)?
Count
Row %
6
54.5%
2
18.2%
3
27.3%
11
e. Require an application for out of state reg ulatory officials?
Count
Row %
5
45.5%
3
27.3%
3
27.3%
11
f. Have an application for out of state reg ulatory officials
available on the PMP website?
Count
Row %
5
45.5%
4
36.4%
2
18.2%
11
g . Require there be an open-investig ation prior to releasing
data to out of state reg ulatory officials?
Count
Row %
8
72.7%
1
9.1%
2
18.2%
11
h. Require a case number from the out of state reg ulatory
official prior to releasing ?
Count
Row %
6
54.5%
3
27.3%
2
18.2%
11
i. Require additional information prior to releasing data to out
of state reg ulatory officials? (If Yes - please explain in the text
box below):
Count
Row %
5
45.5%
6
54.5%
0
0 .0 %
11
T otals
T otal Responses 11
13. Out of State Regulatory Officials12. Does your PMP…
ResponseID Response
7 Case number, type, and descriptionf. Must be notarized if submitted using a form.
Deceased patients require a subpoena.
15 Law Enforcement or a Reg ulatory Ag ency is required to submit a formal request on
letterhead, summarizing the existing investig ation, the need and scope of information
requested. Federal, State, or County Law enforcement officers, investig ative ag ents of
federal, state, or county law enforcement or reg ulatory ag encies, United States
attorneys, county prosecuting attorneys, or the attorney g eneral; provided that the
Controlled Substance Administrator has reasonable g rounds to believe that the
disclosure of any information collected under this part is in furtherance of an ong oing
criminal or reg ulatory investig ation or prosecution
16 Law Enforcement or a Reg ulatory Ag ency is required to submit a formal request on
letterhead, summarizing the existing investig ation, the need and scope of information
requested. Federal, State, or County Law enforcement officers, investig ative ag ents of
federal, state, or county law enforcement or reg ulatory ag encies, United States
attorneys, county prosecuting attorneys, or the attorney g eneral; provided that the
Controlled Substance Administrator has reasonable g rounds to believe that the
disclosure of any information collected under this part is in furtherance of an ong oing
criminal or reg ulatory investig ation or prosecution;
25 Require proof of open & current investig ation for licensing /reg ulatory board requests.
26 ag ain they are required to g o throug h the appropriat in state ag ency and then to the
PMP
14. If you answered Yes to question (i) please include your explanation in thefollowing text box:
15. Release of Audit T rail Data13. Does your law allow the release of an accountholder’s audit trail to himself, the patient, or an outside entity? (An audit trail is arecord of patient searches performed by an account holder in the PMP.)
54% a. Yes54% a. Yes
46% b. No46% b. No
Value Percent Responses
a. Yes 53.8% 14
b. No 46.2% 12
T o ta ls : 26
Yes No N/A Responses
a. Provide the account holder with a history of their
searches performed?
Count
Row %
14
10 0 .0 %
0
0 .0 %
0
0 .0 %
14
b. Restrict which account holders can view their own
searches performed?
Count
Row %
3
21.4%
11
78.6%
0
0 .0 %
14
c. Release a deleg ate's searches to the prescriber or
pharmacist account holder that they are querying the PMP
on behalf of?
Count
Row %
12
85.7%
1
7.1%
1
7.1%
14
d. Release an account holder's audit trail at the request of
law enforcement?
Count
Row %
6
42.9%
6
42.9%
2
14.3%
14
e. Require a subpoena for law enforcement to receive an
account holder's audit trail?
Count
Row %
9
64.3%
3
21.4%
2
14.3%
14
f. Require a search warrant for law enforcement to receive
an account holder's audit trail?
Count
Row %
4
28.6%
5
35.7%
5
35.7%
14
g . Release an account holder's audit trail at the request of a
state reg ulatory official or health licensing board?
Count
Row %
13
92.9%
1
7.1%
0
0 .0 %
14
h. Require there be an open-investig ation prior to
releasing data to state reg ulatory officials?
Count
Row %
11
78.6%
1
7.1%
2
14.3%
14
i. Require a case number from the state reg ulatory official
prior to releasing ?
Count
Row %
9
64.3%
3
21.4%
2
14.3%
14
16. Release of Audit T rail Data14. Does your PMP…
j. Release an account holder's audit trail to the person's
employer?
Count
Row %
0
0 .0 %
14
10 0 .0 %
0
0 .0 %
14
k. Release an account holder's audit trail to the patient?
Count
Row %
4
28.6%
10
71.4%
0
0 .0 %
14
l. Require an application prior to releasing an account
holder's audit trail to a person or entity other than himself?
Count
Row %
4
28.6%
4
28.6%
6
42.9%
14
m. Require additional information prior to releasing audit
trail data? (If Yes - please explain in the text box below):
Count
Row %
7
50 .0 %
2
14.3%
5
35.7%
14
T otals
T otal Responses 14
Yes No N/A Responses
ResponseID Response
2 Proof of identity of the requestor
8 For law enforcement or reg ulatory official, there must be an open investig ation.
19 patients may request an account of who has queried them in the PDMP. T hey do not
request a provider's full audit trail
23 A certification of the request must accompany all requests
25 Patients can request the request history of who has searched them in the PDMP but
cannot request an audit trail for a specific provider.
30 Must complete form that is notorized
31 A person can request an audit trail on searches performed by account holders but only
searches on that person.
17. If you answered Yes to question (m) please include your explanation in thefollowing text box: