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Position Statement

StoppNow

Stop The Organized Pill Pushers Now

Broward County, Florida

FL PDMP: E-Forcse

1. Rules and/or laws that enhance the PDMP and do not constrain the primary purpose of the PDMP

The primary purpose of the Harold Rogers Prescription Drug Monitoring Program is to enhance the capacity of regulatory and law enforcement agencies to collect and analyze controlled substance

2. Mandatory participation (data entry AND review) by “controlled substance prescribing” physicians to both review and input patient Schedule II and III drugs. Definition of “Controlled Substance Prescriber, S. 456.44, adopted by FL Board of medicine and effective January 1, 2012. FL Drug Act: S. 893.03, .04

3.  Lessen the compliance time from 7 days to real time and create a quality assurance measure of compliance with ramifications for non-compliance to the “controlled substance prescriber’s” privileges.

4.  Inter-state exchange: According to ONDCP, who referred us to the NABP: The NABP InterConnect is now fully operational and allows users of PMPs in Arizona, Arkansas, Colorado, Connecticut, Delaware, Illinois, Indiana, Kansas, Kentucky, Louisiana, Michigan, Minnesota, Mississippi, New Mexico, North Dakota, Ohio, South Carolina, South Dakota, Tennessee, Virginia, and Wisconsin to securely exchange prescription data between the 21 participating states. NABP continues to work with other state PMPs to facilitate their participation in the NABP InterConnect. It is anticipated that approximately 30 states will be sharing data or in an MOU to share data using NABP InterConnect in 2013.

5.  Permanent sustainable funding system.

6.  Continued education of prescribers, dispensers, users, owners of the PDMP FL Statute 462 Secondary disclosure is a felony.

FL Regulatory Board Accountability

The FL “governor” appointed Board of Medicine, Board of Osteopathy, Board of Pharmacy and Board of Dentistry:

Disciplinary performance should be audited every 6 months on the outcome decisions of all cases of high prescribing doctors/dentists heard by the boards. The audits are to be conducted by Drug Court Judges and/or Medical Examiners or other 3rd party, rotating from county to county within the state. And in the occasion of a sentinel event, such as death or devastating bodily harm from a prescribed Schedule II drug, immediate license suspension of the offending prescriber must occur as the lives of FL citizens are in imminent danger.

 

Controlled Substance Prescriber Definition

Recommendations:

Revision and Strengthening

Controlled Substance Prescriber – In accordance with s. 456.44, Florida Statutes, a physician licensed under chapter 458, chapter 459, chapter 461, or chapter 466 who prescribes any controlled substance, listed in Schedule II, Schedule III, or Schedule IV as defined in s. 893.03, for the treatment of chronic nonmalignant pain, must designate himself or herself as a controlled substance prescribing practitioner on the physician’s practitioner profile.

“Chronic nonmalignant pain” means pain unrelated to cancer which persists beyond the usual course of disease or the injury that is the cause of the pain or more than 90 days after surgery.

FL “Controlled Substance Prescriber” (previously known as “Dispensing Practitioner” which called for a fee of $100.00 regardless of the physician applicants disciplinary status) needs statutory change so that the rules (Administrative Code) governing any physician who applies for and is granted this privilege of must in addition to being registered with the DOH/MQA understand and comply with the following minimum and continuing requirements:

Medical staff privileges at a local (to be defined) hospital.

Mandatory use of the PDMP with rules for non-compliance.

Subject to both announced and unannounced audits conducted by the FL DOH/MQA.

Should a DEA investigation result in seizure of patient records, 100% of patient records will be reviewed and an “emergency suspension” of your medical license will be given until completion of the review, regardless of “ownership” of patient records.

Mandatory reporting of sentinel events, such as a patient death or significant (to be defined) adverse effect of the controlled substance prescribed, will result in an “emergent” review of patient records prescribed the same drug.

“Emergency Suspension” order will be given in the like manner and comparable to sexual assaults of patients.

Continuing documented education on pain management, and opioids by an entity who has NOT received monies from a pharmaceutical company.

The above is a summary of suggested minimum requirements for FL defined “Controlled Substance Prescribers”. This does NOT affect any physician who has not been granted or who has not applied for the privilege of prescribing controlled substances for chronic non-malignant pain.