In a letter delivered today to state senators, MMS President Lynda Young, M.D. shared physician concerns on Senate 2122, An Act Relative to Prescription Drug Diversion, Abuse and Addiction, proposed legislation intended to address the growing problem of prescription drug abuse in the Commonwealth. Here is the text of her letter:
The Massachusetts Medical Society shares your concern over high rates of opioid abuse in Massachusetts. The Society works closely with the legislature and the Patrick administration to address the problem and frequently hosts events targeted at educating physicians regarding responsible prescribing habits, pain management, drug diversion and patient education. Most recently, the MMS collaborated with the Board of Registration in Medicine to implement CME’s for physicians on pain management. We are proud of our efforts to reduce prescription drug addiction and diversion, but realize more could, and should be done.
S.2122, “An Act Relative to Prescription Drug Diversion, Abuse and Addiction” is a good multi-pronged approach to the problem of prescription drug abuse. The MMS supports language in the bill designed to increase the usefulness of the prescription monitoring program as a valuable clinical tool in prescription decisions. We support the production and distribution of educational materials to inform and enlist consumers in actions that will protect their families from access to narcotics and help patients decide their treatment options. We strongly support the provision of limited immunity from drug possession charges and prosecution when a drug related overdose victim or a witness to an overdose seeks medical attention. The Society also looks forward to working with the Executive Office of Health and Human Services on a joint policy group to investigate best practices for reducing diversion, abuse and addiction.
However, the Society must register its concern regarding S.2122’s mandate that all prescribers enroll in the Prescription Drug Monitoring Program, some by next January, and utilize the program before prescribing any schedule II or schedule III drug. While a very useful tool, the PDMP is still evolving and the MMS questions its ability to accommodate the needs of twenty thousand or so new practitioners in a timely and useful manner. For some physicians, including those who may fall into the “high prescriber” category like emergency physicians, time is of the essence. Primary care providers have a jam-packed schedule and checking with the program several times a day during a patient visit may extend waiting times for patients, extend clinical hours for overworked clinicians and distract providers from patient care issues unrelated to abuse. What if the system is down, or unavailable? Would the physician be prohibited from writing the necessary prescription?
First it is essential that the DPH has the capacity to develop good quality data on prescriptions and that the data is accurate and meaningful. A phased-in registration process that begins with high volume prescribers of schedule II opioids is a reasonable approach which we support. Mandating review of patient records in the PMP prior to an initial prescription for oxycontin is a reasonable approach to gain value from the PM P.
The legislation should require the DPH to make outreach efforts to all prescribers detailing the program’s benefits and making free and quick on-line registration for physicians available before mandates are initiated. By working with Board of Registration, the DPH could issue secure passwords and registrations to all actively licensed providers with prescribing privileges in the Commonwealth.
Coming on the heels of last year’s mandate for pain management CME’s for all physicians who write prescriptions for any medication, the MMS would further suggest that the working group created in Section 18 of S.2122 should begin its investigation and study into best practices for reducing drug abuse, and that those recommendations be considered prior to any further legislative mandates or requirements. One point for consideration is to remove mandates for pain management training for physicians who do not write prescriptions for opiates and other pain medications.
In conclusion, the MMS appreciates the efforts of Senator John Keenan and the Mental Health and Substance Abuse Committee and looks forward to continuing to work on revisions to S.2122 and other initiatives to reduce prescription drug abuse.
Lynda M. Young, M.D., F.A.A.P.