There is a national movement at both the State and Federal level on making PDMP a requirement prior to initiating opioid therapy. From my perspective creating a financial incentive for physician's to utilize PDMP would go a long way towards more rapid adoption. As it turns out, HHS/CMS has released a draft of proposed legislation around this:

(https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf)

Summary: https://www.cms.gov/Medicare/Quality-Initiatives-P...

This is open to public comment now until June 27, 2016. I am submitting a comment strongly advocating reimbursing physicians more highly for this. Please sign this petition to indicate your support for reimbursing physicians for participating in the prescription drug monitoring program. When you sign the petition, please include your title, organization (Methodist Hospital), city and zip code in the comments box, because the Department of Health and Human Services requests this information from all those who submit a petition. Below is a version of the petition as well as a link to a summary of the proposed MACRA changes.

Sincerely,

Ezekiel Fink, MD

Director of Inpatient Pain

Houston Methodist Hospital

Comment:

RE: Centers for Medicare & Medicaid Services

42 CFR Parts 414 and 495

[CMS-5517-P] RIN 0938-AS69

Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for

Physician-Focused Payment Models

Regarding the call for feedback related to the weight of CPIAs on pg. 334: “We seek comment on which activities should receive a high weight as opposed to a medium weight”, on behalf of the following healthcare practitioners: (include link to petition site), we encourage CMS to upgrade the weight of PDMP utilization from “medium” to “high”.

Participation in the Prescription Drug Monitoring Program (PDMP) is a specific activity under the Clinical Practice Improvement Activities (CPIA) category that providers will receive credit for which will count towards their total Merit-based Incentive Payment System (MIPS) score and subsequent adjustments in CMS payments through MIPS. While there are two categories of CPIA activities as a means of receiving enhanced quality-related payments, medium and high, currently under the Patient Safety and Practice Assessment Section of the CPIA activities, engaging in the PDMP is weighted as a “medium” CPIA activity.

By upgrading the priority weighting of PDMPs in relation to other CPIAs, engaging in PDMPs would count more significantly towards the MIPS score and incentives and would encourage practitioners to prioritize engaging in PDMP activities. If PDMP participation is weighted more heavily in MIPS scoring, clinicians will adopt PDMP utilization more rapidly due to the financial incentives related to MIPS scoring.

Additionally, there appears to be inconsistent language relating to the CPIA weighting of PDMPs. On the MACRA NPRM list of CPIAs on pg. 957, it lists PDMP activities as “medium”:

“Annual registration by eligible clinician or group in the prescription drug monitoring program of the state where they practice. Activities that simply involve registration are not sufficient. MIPS eligible clinicians and groups must participate for a minimum of 6 months. (Medium)”

However, in the section describing the criteria which is used to determine the level of financial incentives provided through the MIPS program (pg. 166), PDMP is listed as a “high” priority CPIA:

"While we considered both equal and differentially weighted scoring in this performance category, the statute requires a differentially weighted scoring model by requiring 100 percent of the potential score in the CPIA performance category …. Programs that require performance of multiple activities such as participation in the Transforming Clinical Practice Initiative, seeing new and follow-up Medicaid patients in a timely manner in the provider's State Medicaid Program, or an activity identified as CMS-5517-P TLP 4/25/16 167 a public health priority (such as emphasis on anticoagulation management or utilization of prescription drug monitoring programs) were weighted as high. The statute references patient-centered medical homes as achieving the highest score for the MIPS program. MIPS eligible clinicians or groups may use that to guide them in the criteria or factors that should be taken into consideration to determine whether to weight an activity medium or high on comments for this proposal. We request comments on this proposal, including criteria or factors we should take into consideration to determine whether to weight an activity medium or high."

Again on pg. 334 PDMP is referenced as a “high” priority CPIA:

"Consistent with our CMS-5517-P TLP 4/25/16 334 unified scoring system principles, MIPS eligible clinicians would know in advance how many potential points they could receive for each CPIA. Activities are proposed to be weighted as high based on the extent to which they align with activities that support… Additionally, activities that require performance of multiple actions, such as participation in the Transforming Clinical Practice Initiative, participation in a MIPS eligible clinician's state Medicaid program, or an activity identified as a public health priority (such as emphasis on anticoagulation management or utilization of prescription drug monitoring programs) are justifiably weighted as high. We seek comment on which activities should receive a high weight as opposed to a medium weight."

Since the CPIA program is a significant factor in determining the MIPS score and incentive payments to clinicians, we recommend that CMS deem PDMP activities as “high” weight consistently throughout the listing of CPIA weights. This will ensure that PDMP related MIPS scoring will be commensurate with the relative importance of PDMP as a CPIA activity, resulting in rapid adoption and utilization of the PDMP.