C U S T O M E R D R I V E N. B U S I N E S S M I N D E D.

Transcription

1 MAPS Update May 4, 2018 Presented by Kim Gaedeke, Acting Deputy Director Department of Licensing and Regulatory Affairs Andrew Hudson, Manager Drug Monitoring Section

2 Bureau of Professional Licensing Established in July Occupational Licensing/Regulation Boards 27 Health Professional Licensing/Regulation Boards Boards are advisory and determine sanctions License and regulate over 758,000 individuals 3 Divisions: Licensing, Investigations & Inspections, Enforcement Drug Monitoring Section: Administers Michigan Automated Prescription System (MAPS) and investigates overprescribing, over dispensing, and drug diversion

3 MAPS Background Contains over 120 million records Data maintained for 5 years Required reporting of CS Schedule 2-5 from: Prescribers who dispense CS Schedule 2-5 Pharmacists (dispensers) Veterinarians

4 Governor s Prescription Drug and Opioid Task Force Created in June 2015 Multiple recommendations by Task Force, included updating or replacing MAPS Complete Task Force Recommendation report can be found at: > Lt. Governor > Initiatives > Prescription Drug & Opioid Task Force June 2016 Governor established by EO ( ) the Prescription Drug & Opioid Abuse Commission

5 MAPS Replacement Project MAPS replaced with new system software Vendor: Appriss Health s PMP AWARxE 6 month project started in October 2016 Successfully launched and implemented on April 4, 2017 All users of the old system had to create a new account with MAPS through the PMP AWARxE software Continue to seek feedback from Stakeholders

6 PMP AWARxE- Registration

7 PMP AWARxE- Registration Once user role is chosen, user will be prompted to enter identification criteria, including but not limited to: address, phone number Once identification criteria is submitted, user is prompted to complete and attach Registration Form The supervisor listed on the users registration must match the supervisor listed on application

8 PMP AWARxE- Registration

9 Registration to MAPS

10 PMP AWARxE- Dashboard

11 PMP AWARxE User Profile Delegate users able to add additional supervisors or remove, and Supervisors are able to manage their Delegate users

12 MAPS Requests LARA may provide MAPS data to: A state, federal, or municipal employee or agent whose duty is to enforce the laws of this state or the United States relating to drugs, for bona fide drugrelated criminal investigatory or evidentiary purposes. MCL a(2)(c) and (3). Bona fide drug-related criminal investigatory or evidentiary purposes include, for example: Investigating illegal distribution or possession of controlled substances Prescription fraud Driving under the influence of a controlled substance

13 MAPS Requests Examples of searches that would not be approved because they are not for a bona fide drug-related criminal investigatory or evidentiary purposes: Missing persons (includes parolees or probationers). Administrative investigations of other law enforcement officers. Also, requests for info regarding non-cs are denied because MAPS only tracks CS schedules 2-5.

14 MAPS Requests This information shall not be provided to any other person or entity except by order of a court of competent jurisdiction. MCL a(4) All law enforcement officers and all officers of the court in using MAPS data for investigatory or prosecution purposes, shall consider the nature of the prescriber s and dispenser s practice and the condition for which the patient is being treated. MCL a(8)

15 MAPS Requests Once search is submitted, a message will appear indicating the request has been submitted to Admin for approval.

16 MAPS - NarxCare Report

17 MAPS NarxCare Report (continued)

18 MAPS NarxCare Report (continued)

19 MAPS NarxCare Report (continued)

20 MAPS NarxCare Data Narx Scores and Predictive Risk Scores (overdose) Scores: based on algorithms, including MMEs, number of prescribers and pharmacies Scores: Ranges from ; higher scores equate to higher risk and misuse Red Flags Rx Graphs PDMP Data

21 MAPS Requests

22 Contact MAPS Staff: Does this request fall under bona fide drug-related criminal investigatory or evidentiary purposes? Is this drug/prescription considered a CS Schedule 2-5? Unsure of how to submit a report request? Please contact MAPS Support Team: or BPL-MAPS@Michigan.gov

23 Regulatory Actions

24 Regulatory Actions In August 2016, LARA created a permanent Drug Monitoring Section to identify, investigate, and pursue administrative actions against health professionals who overprescribe, overdispense, and divert controlled substances. Focused on supply reduction of medically unnecessary controlled substances that feed addiction and overdose. Since the inception of DMS, LARA has summarily suspended forty-four licensees based on evidence of overprescribing or overdispensing

25 Controlled Substance Prescriptions Filled in Michigan by Year Total CS prescriptions dispensed % change from previous year ,007, ,400, % ,876, % ,954, % ,763, % ,991, % ,728, % ,904, % ,472, % ,092, % ,943, %

26 Enforcement Actions - Outcomes Since March 2016, LARA and the AG have taken disciplinary action against 46 prescribers. 29 of those actions included summary suspensions of the professional license because the public health, safety, and welfare, required emergency action. Controlled Substance Prescriptions Dispensed Years 2015 and 2017 Drug % Change Alprazolam 2mg 10,227,915 6,939, % Alprazolam 1mg 41,299,216 34,379, % Hydrocodone/Acetaminophen 10mg 177,326, ,080, % Hydrocodone/Acetaminophen 7.5mg 107,776,175 84,705, % Carisoprodol 350mg 13,124,785 7,808, % Oxycodone 30mg 16,666,622 12,306, % Promethazine w/ Codeine 41,758,634 28,579, %

27 Case examples

28 Prescriber X MAPS data for January 1, 2015, through March 31, 2017, indicated the following: 79.28% of the controlled substance prescriptions issued by Prescriber X were for Alprazolam, Carisoprodol, Hydrocodone 10mg, or Promethazine with Codeine 42% of the controlled substance prescriptions written by Prescriber X were filled by patients who paid cash 42% of the controlled substance prescriptions issued by Prescriber X were filled at the same independent pharmacy Additionally, Prescriber X had a history of prescribing to doctor-shopping patients (7 in less than 2 years), did not regularly request MAPS data on his patients, and had a known history of mental illness.

29 Prescriber X timeline LARA Pre-Investigation/MAPS Review: Requested authorization for investigation due to possible overprescribing Investigation: Investigation authorized Medical records subpoenaed and Prescriber X interviewed Expert review of medical records revealed numerous deviations from the standard of care Outcome: Complaint drafted Summary suspension served Prescriber X agreed to permanently surrender his controlled substance license and agreed to an 18-month suspension of his license to practice medicine

30 Prescriber Y LARA Pre-Investigation/MAPS Review: Drug Licensee's 2015 rank Licensee's 2016 Q3 rank Licensee's 2016 Q4 rank (a) Alprazolam 1 mg N/R 3 4 (a) Carisoprodol (a) Codeine/promethazine syrup (a) Hydrocodone combination products (a) Hydrocodone combination products 10 mg N/R 7 4 (a) All controlled substances N/R 43 19

31 Prescriber Y MAPS data for January 1, 2015 through August 14, 2017 indicated the following: Nearly 22% of the controlled substance prescriptions written by Prescriber Y were filled by patients who paid cash Nearly 10% of the controlled substance prescriptions Prescriber Y wrote were for patients who traveled from more than 70 miles away Additionally, expert review of a sampling of Prescriber Y s medical records showed he did not perform adequate pain assessments, failed to assess patients for risk of addiction, and failed to take adequate safeguards to detect misuse, abuse, or diversion of controlled substances.

32 Prescriber Y

33 Pharmacy X LARA Pre-Investigation/MAPS Review: Drug Respondent s 2015 Rank Respondent s 2016 Rank Respondent s 2017 Q1 Rank (a) Alprazolam 2 mg (a) Carisoprodol (a) Codeine/Promethazine Syrup 5 2 2

34 Pharmacy X LARA Pre-Investigation/MAPS Review: Drug thru May 29 (a) Oxycodone 30 mg 8 (0.17%) 0 0 (a) Hydrocodone/Apap, All Strengths 1407 (29.54%) 1243 (25.63%) 325 (17.33%) (a) Alprazolam 1 mg 345 (7.24%) 386 (7.96%) 115 (6.13%) (a) Alprazolam 2 mg 461 (9.68%) 432 (8.91%) 191 (10.19%) (a) Carisoprodol 350 mg 634 (13.31%) 489 (10.08%) 245 (13.07%) (a) Codeine with Promethazine 1061 (22.28%) 1373 (28.31%) 553 (29.49%) (a) Total, (a) - (f) (percentage of all CS prescriptions dispensed) 3916 (82.22%) 3923 (80.89%) 1429 (76.21%) (a) Total CS Prescriptions

35 Pharmacy X MAPS data for January 1, 2015, through May 29, 2017, indicated the following: Throughout the above time period, over 30% of the controlled substances dispensed by Pharmacy X were paid for with cash Greater than 30% of the controlled substances dispensed by Pharmacy X were pursuant to prescriptions written by home-visiting physicians who travelled a great distance to treat patients and who consistently prescribed combinations of opioids and benzodiazepines Additionally, MAPS data for 2017 identified 5 patients who received opioidbenzodiazepine combinations from 5 or more providers Pharmacy X s pharmacist-in-charge (PIC) had previously had his license suspended for drug diversion An inspection conducted by Bureau investigators revealed an unexplained loss of 1,053 pills of 350mg Carisoprodol from Pharmacy X s inventory

36 Pharmacy X timeline LARA Pre-Investigation/MAPS Review: Requested authorization for investigation due to possible over-dispensing Investigation: Investigation authorized Inspection & audit conducted Interviewed PIC Contacted wholesale distributors Compiled all info drafted investigation report approved Outcome: Complaint drafted Summary suspension served/seizure of controlled substances in August 2017 Pharmacy agreed to permanently surrender its controlled substance license in February 2018

37 Pharmacy Y LARA Pre-Investigation/MAPS Review: Drug Respondent s 2016 Rank Respondent s 2017 Q2 Rank (a) Codeine/Promethazine Syrup (a) Oxycodone 30 mg (a) Oxymorphone (all strengths) (a) Oxymorphone 40 mg

38 Pharmacy Y

39 Pharmacy Y LARA Pre-Investigation/MAPS Review: Requested authorization for investigation due to possible over-dispensing Investigation: Investigation authorized Inspection & audit conducted Interviewed PIC; discovered he had a history of licensing suspensions and substance abuse Contacted wholesale distributors Compiled all info drafted investigation report approved Outcome: Complaint drafted Summary suspension served/seizure of controlled substances in November 2017 in coordination with MSP Litigation is ongoing; both the pharmacist and the pharmacy s controlled substance license remain suspended

40 Questions? Thank You!