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Ph 1 harris hanna_slack
1. Pharmacy
Track:
Improving
Communica5ons
with
Physicians
Patrice
A.
Harris,
MD
Catherine
Hanna,
RPh.
PharmD
P.
Tennent
Slack,
MD
2. • Patrice
A.
Harris
has
no
financial
rela;onships
with
proprietary
en;;es
that
produce
health
care
goods
and
services.
• Catherine
Hanna
has
no
financial
rela;onships
with
proprietary
en;;es
that
produce
health
care
goods
and
services.
• P.
Tennent
Slack
has
no
financial
rela;onships
with
proprietary
en;;es
that
produce
health
care
goods
and
services.
Disclosures
3. 1.
Outline
the
strategies
for
collabora;ng
across
professional
lines
for
the
adequate
treatment
of
pa;ents.
2.
Describe
best
prac;ces
for
dispensers
to
communicate
with
prescribers.
3.
Evaluate
the
challenges
for
health
care
professionals
in
communica;ng
about
their
pa;ents
and
offer
solu;ons.
Objec;ves
4. America’s
Rx
drug
abuse
and
diversion
crisis
Patrice A. Harris, MD
National Rx Drug Abuse Summit
April 2014
5. Goals
of
presenta;on
• What
is
the
AMA’s
interest
in
“pain”?
• Enhancing
educa;on
• Challenges
facing
health
care
professionals
• Par;ng
thoughts
5
6. The
AMA
interest
in
“pain”
• Support
legisla;on
to
combat
prescrip;on
drug
abuse
and
diversion
• Enhance
educa;on
and
appropriate
efforts
to
ensure
access
to
appropriate
pain
management
• Increase
access
to
treatment
for
substance
abuse
and
addic;on
6
19. Enhancing
educa;on
• What
happens
medical
school/residency?
• What
is
required
state-‐by-‐state?
• Incen;vizing
educa;on
–
why
aren’t
there
more
to
help
treat
addic;on?
• Just
what
do
we
mean/want
by
“specialist”?
19
20. The
AMA
interest
in
“pain”
• Suppor;ng
legisla;on
to
combat
prescrip;on
drug
abuse
and
diversion
• Enhancing
educa;on
and
appropriate
efforts
to
ensure
access
to
appropriate
pain
management
• Increasing
access
to
treatment
for
substance
abuse
and
addic;on
20
22. Curbing
Prescrip;on
Drug
Abuse
and
Misuse:
Communica;ng
with
Providers-‐
Best
Prac;ces
and
the
Role
of
Pharmacists
Catherine
Hanna,
RPh.
PharmD
KY
Board
of
Pharmacy
Vice
President
of
Professional
Affairs
American
Pharmacy
Services
Corpora;on
23. • One
of
the
main
problems
health
care
professionals
see
when
having
difficulty
communica;ng
with
other
health
care
professionals
comes
down
to
knowledge,
respect
and
understanding
of
the
situa;on
at
hand
and
the
challenges
faced
by
each
other.
Improved
educa-on
and
communica-on
is
essen-al!
Improving
Communica;ons
Between
Health
Care
Professionals
24. • Increased
focus
on
illness
and
deaths
caused
by
inappropriate
use
of
controlled
substances
—
in
par;cular
opioid
analgesics.
• Opioid
prescrip;ons
have
increased
drama;cally
which
has
led
to
a
significant
increase
in
prescrip;on
drug
diversion,
abuse
and
misuse
and
a
substan;al
increase
in
the
number
of
deaths
due
to
overdose.
Why
We
are
Here?
25. • In
the
mid-‐1990s,
advocates
for
treatment
of
chronic
pain
began
arguing
that
pain
was
largely
untreated.
• New
formula;ons
of
opioid
agents
became
available,
with
purported
advantages
in
analgesia.
• Inappropriate
prescribing
has
also
increased
drama;cally.
Primarily
in
Pill
Mills
Why
We
are
Here?
26. • Pharmacies
report
that
DEA
agents
are
inspec;ng
prescrip;ons
and
other
records.
• DEA
agents
are
focusing
primarily
on
opiods
and
poly-‐substance
prescribing,
large
doses
and
long-‐
term
therapy.
• DEA
agents
are
also
looking
for
red
flags
from
controlled
substance
data
and
prescriber’s
prescribing
paierns
and
the
prac;ce
site.
What
Is
Happening?
27. • In
several
states
providers
have
reported
that
they
are
experiencing
problems
with
pharmacists
refusing
to
fill
pa;ent’s
controlled
substance
prescrip;ons.
• Certain
pharmacies
reportedly
are
requiring
pa;ent
informa;on
such
as
diagnosis
codes,
treatment
history,
dura;on
of
therapy,
treatment
plans
and
payment
method
prior
to
filling
a
prescrip;on.
What
Is
Happening?
28. • This
informa;on
is
not
required
by
state
or
federal
law
but
the
DEA
inves;ga;on
and
discipline
process
have
prompted
changes
in
some
pharmacy
policies.
• Federal
privacy
laws
permit
doctors
to
share
pa;ent
informa;on
for
treatment
purposes
with
pharmacists.
What
Is
Happening?
29. • Verifica;on
of
addi;onal
requested
informa;on
may
take
extra
;me
on
the
part
of
the
prescriber.
Is
this
informa;on
necessary
to
fulfill
the
role
of
the
pharmacist
in
reducing
the
poten;al
abuse
of
controlled
substances?
• A
pharmacist
can
refuse
to
fill
a
prescrip;on
if
professional
judgment
suggests
the
prescrip;on
is
in
viola;on
of
federal
or
state
law,
would
not
be
in
the
best
interest
of
the
pa;ent,
or
is
being
used
to
con;nue
an
addic;on
or
habit.
What
Is
Happening?
30. • Pharmacies
have
a
role
to
play
in
the
oversight
of
prescrip;ons
for
controlled
substances.
Under
the
Controlled
Substances
Act,
pharmacists
must
evaluate
each
controlled
substance
prescrip;on
to
ensure
that
it
is
appropriate.
• State
boards
of
pharmacy
regulate
the
distribu;on
of
opioids
and
other
controlled
substances
as
mandated
by
state
and
federal
regula;ons.
Understanding
the
Pharmacists
Liability
31. • In
the
majority
of
cases
of
poten;al
abuse,
pharmacists
face
a
pa;ent
who
has
a
legal
prescrip;on
from
a
licensed
prescriber
without
actually
having
access
to
pa;ent
background
informa;on.
• This
can
make
it
difficult
for
the
pharmacist
because
they
may
not
always
have
all
the
informa;on
they
need
to
make
an
completely
informed
decision
and
must
rely
on
their
“gut”
in
some
situa;ons.
Understanding
the
Pharmacists
Liability
32. • Corresponding
responsibility
is
one
of
the
most
commonly
misunderstood
and
in
some
cases
unknown
concepts
found
in
DEA’s
regula;ons.
• Enforcement
ac;ons
are
generally
ini;ated
against
pharmacists
and
pharmacies
when
a
pharmacist
fails
to
exercise
his/her
corresponding
responsibility.
Corresponding
Responsibility
33. • The
DEA’s
regula;ons
(21
C.F.R.
§
1306.04)
addressing
corresponding
responsibility
states:
– A
prescrip;on
for
a
controlled
substance
to
be
effec;ve
must
be
issued
for
a
legi;mate
medical
purpose
by
an
individual
prac;;oner
ac;ng
in
the
usual
course
of
his
professional
prac;ce.
The
responsibility
for
the
proper
prescribing
and
dispensing
of
controlled
substances
is
upon
the
prescribing
prac;;oner,
but
a
corresponding
responsibility
rests
with
the
pharmacist
who
fills
the
prescrip;on.
– An
order
purpor;ng
to
be
a
prescrip;on
issued
not
in
the
usual
course
of
professional
treatment
or
in
legi;mate
and
authorized
research
is
not
a
prescrip;on
within
the
meaning
and
intent
of
sec;on
309
of
the
Act
(21
U.S.C.
829)
and
the
person
knowingly
filling
such
a
purported
prescrip;on,
as
well
as
the
person
issuing
it,
shall
be
subject
to
the
penal;es
provided
for
viola;ons
of
the
provisions
of
law
rela;ng
to
controlled
substances.
Corresponding
Responsibility
34. • What
does
this
mean?
The
regula;on
states
that
the
pharmacist
is
in
the
same
posi;on
as
the
prescriber
who
issued
the
prescrip;on
and
must
exercise
professional
judgment
to
determine
whether
a
prescrip;on
for
a
controlled
substance
was
issued
for
a
legi;mate
reason
and
to
a
legi;mate
pa;ent.
• Problem
in
the
eyes
of
the
pharmacist:
without
having
actually
conducted
a
medical
examina-on
of
the
pa-ent
Corresponding
Responsibility
35. • DEA
has
made
it
clear
that
pharmacists
must
iden;fy
and
resolve
certain
red
flags
before
a
prescrip;on
for
a
controlled
substance
is
dispensed.
Corresponding
Responsibility
36. • Does
iden;fying
red
flags
mean
you
are
exercising
your
corresponding
responsibility
as
required?
• Are
pharmacists
exercising
corresponding
responsibility
appropriately
when
they
decide
not
to
dispense
controlled
substances
to
a
pa;ent
whose
prescrip;on
sets
off
one
or
more
red
flags?
• How
many
red
flags
of
what
combina;on
of
red
flags
must
be
iden;fied
for
a
pharmacist
to
refuse
dispensing
a
prescrip;on?
Corresponding
Responsibility
and
the
Red
Flags
Ques;ons
37. • The
pharmacist
can
not
simply
defer
to
the
prescriber
and
is
expected
to
exercise
independent
professional
judgment
when
determining
if
a
prescrip;on
was
issued
for
a
legi;mate
purpose
by
a
prescriber
ac;ng
in
the
usual
course
of
professional
judgment.
• Merely
contac;ng
the
physician
for
verifica;on
that
the
prescrip;on
was
wriien
by
that
prescriber
may
not
be
sufficient
to
fulfill
the
pharmacist’s
duty,
and
the
pharmacist
should
refuse
to
fill
the
prescrip;on
if
there
is
reasonable
suspicion
that
it
is
not
valid.
Corresponding
Responsibility
and
the
Red
Flags
38. • A
pharmacist
who
“knowingly”
fills
a
prescrip;on
that
is
not
issued
in
the
usual
course
of
professional
treatment
is
subject
to
the
penal;es
of
the
Controlled
Substance
Act.
• The
pharmacist
who
decides
to
“look
the
other
way”
and
fills
a
prescrip;on
for
a
controlled
substance
that
he
or
she
knew
or
should
have
known
was
not
for
a
legi;mate
purpose
may
be
subject
to
prosecu;on.
Corresponding
Responsibility
and
the
Red
Flags
39. • The
pharmacist
is
required
to
exercise
sound
professional
judgment
when
determining
the
legi;macy
of
a
prescrip;on
for
a
controlled
substance.
Corresponding
Responsibility
and
the
Red
Flags
40. • “Paiern
prescribing’’
–
prescrip;ons
for
the
same
drugs
and
the
same
quan;;es
coming
from
the
same
doctor,
strengths/no
varia;on
in
the
quan;ty
and
strength
between
pa;ents
• Prescribing
combina;ons
or
“cocktails”
of
frequently
abused
controlled
substances
• Geographic
anomalies-‐
A
prescriber’s
prescrip;on
paiern
is
different
from
that
of
other
prescribers
in
the
area
(e.g.,
more
prescrip;ons
for
controlled
substances
or
prescrip;ons
for
larger
quan;;es
of
controlled
drugs)
Red
Flags
May
Contain
41. • Is
the
prescriber
not
familiar
to
the
pa;ent
or
is
the
provider
and/
or
the
pa;ent
from
out
of
town
• Shared
addresses
by
customers
presen;ng
on
the
same
day
• The
prescribing
of
controlled
substances
in
general
• Quan;ty
and
strength-‐large
quan;;es
and
strengths
• Paying
cash
rather
than
using
insurance
• Customers
with
the
same
diagnosis
code
from
the
same
doctor
Red
Flags-‐con;nued
42. • Prescrip;ons
wriien
by
doctors
for
infirmaries
not
consistent
with
their
area
of
specialty;
• Fraudulent
prescrip;ons
or
prescrip;ons
with
irregulari;es
• Pa;ent
is
asking
for
brand
name
only
or
a
certain
generic
brand
• The
pa;ent
is
overly
friendly
or
nervous
Red
Flags-‐con;nued
43. – Prescriber
writes
for
antagonis;c
drugs
(e.g.,
s;mulant
and
depressant
at
the
same
;me)
– Pa;ent
returns
to
the
pharmacy
more
frequently
than
expected
(e.g.,
prescrip;on
quan;;es
do
not
last
as
long
as
expected)
– Pa;ent
presents
mul;ple
prescrip;ons
for
the
same
drug
wriien
for
different
people
– A
number
of
people
appear
within
a
short
;me
period
for
the
same
controlled
drug
from
the
same
physician,
or
a
large
number
of
previously
unknown
patrons
show
up
with
prescrip;ons
from
the
same
physician
– The
patron
presents
a
prescrip;on
that
shows
evidence
of
possible
forgery
(e.g.,
unusual
direc;ons
or
quan;;es,
no
abbrevia;ons,
apparent
erasures,
unusual
legibility,
evidence
of
photocopying)
Red
Flags
-‐con;nued
44. • The
abuse
and
misuse
of
prescrip;on
drugs
is
a
serious
problem
that
we
all
recognize,
but
has
the
response
by
law
enforcement
and
other
agencies
to
curb
diversion
created
challenges
when
balancing
the
need
for
treatment
of
legi;mate
pa;ents?
• Are
we
seeing
an
environment
where
providers
are
reluctant
to
prescribe
and
pharmacists
are
reluctant
to
dispense
medica;ons
for
legi;mate
pa;ents?
• How
can
the
professions
work
together
to
improve
communica;on
and
collaborate
toward
the
ul;mate
goal
to
curb
prescrip;on
drug
diversion,
abuse
and
misuse
and
insure
that
legi;mate
pa;ents
are
cared
for
appropriately?
Challenges
45. • All
healthcare
providers
need
to
be
aware
of
the
poten;al
for
drug
diversion,
recognize
the
warning
signs
of
possible
misuse
and
abuse
and
acknowledge
the
legal
obliga;ons
we
all
have
to
minimize
improper
prescrip;on
use.
• The
baile
to
prevent
prescrip;on
drug
abuse
while
maintaining
access
to
pa;ents
in
need
is
challenging,
but
both
professions
must
each
realize
the
responsibili;es
of
all
par;es
as
we
work
toward
a
solu;on.
Improving
Communica;ons
Between
Health
Care
Professionals
46. • There
are
many
differences
between
the
professions
of
medicine
and
pharmacy
that
ul;mately
influence
our
understanding
of
the
other
profession.
• It
is
clear
that
effec;ve,
deliberate
prescriber-‐pharmacist
collabora;on,
improved
communica;on
and
working
rela;onships
can
significantly
improve
overall
pa;ent
care
and
help
curb
prescrip;on
drug
diversion,
abuse
and
misuse.
• Efforts
to
improve
these
rela;onships
must
focus
on
the
strategic
introduc;on
of
agreed
changes
working
prac;ces
between
the
two
professions
and
educa;on.
Improving
Communica;ons
Between
Health
Care
Professionals
47. • When
communica;ng
and
collabora;ng
to
improve
pa;ent
care
the
focus
must:
– Place
the
overall
care
of
the
legi;mate
pa;ent
first
– Incorporate
sound
clinical
knowledge
– Incorporate
sound
professional
judgment
– Allow
each
profession
to
act
in
a
collegial
and
collabora;ve
manner
– Be
based
upon
understanding/knowledge
and
respect
of
the
role
and
obliga;ons
of
all
professionals
involved
Improving
Communica;ons
Between
Health
Care
Professionals
48. • Stakeholder:
AMA,
NCPA,
NABP,
CVS,
Walgreens,
NACDS,
Rite
Aid,
American
Academy
of
Family
Physicians,
American
Osteopathic
Associa;on,
Cardinal
Health,
Pharmaceu;cal
Research
and
Manufacturers
of
America
• Consensus
was
that
coordina;on
and
collabora;on
must
be
improved
to
combat
the
issue
of
prescrip;on
drug
abuse
and
diversion
while
also
complying
with
the
corresponding
responsibility
requirements
of
federal
and
state
laws
and
regula;ons.
Stakeholders
Consensus
Document
on
Prescribing
and
Dispensing
Controlled
Substances
50. P.
Tennent
Slack,
MD
Pain
Medicine
/
Anesthesiology
Dept.
of
Interven;onal
Pain
Medicine
Northeast
Georgia
Physicians
Group
51. P.
Tennent
Slack
has
no
financial
rela;onships
with
proprietary
en;;es
that
produce
health
care
goods
and
services
52. 1.
Outline
the
strategies
for
collabora;ng
across
professional
lines
for
the
adequate
treatment
of
pa;ents.
2.
Describe
best
prac;ces
for
prescribers
to
communicate
with
dispensers.
3.
Evaluate
the
challenges
for
health
care
professionals
in
communica;ng
about
their
pa;ents
and
offer
solu;ons.
53. Consequences
Of
Prescribers
Not
Engaging
• Promotes
inaccurate
assump;ons
and
inaccurate
conclusions
– Pharmacists
– Law
enforcement
– Government
officials
– Interested
organiza;ons
–
CDC,
NADDI,
etc.
– The
public
at
large
• Erosion
of
physician
control
over
decisions
that
are
fundamentally
medical
in
nature
54.
55.
56.
57. The
Pain
Treatment
Environment
Elements
of
Discrimina;ng
Prescribing
Opioid
Rx
59. THE
PERFECT
STORM
Pain
• Pain
complaints
are
extremely
common
• Mind-‐body
phenomenon
• Subjec5ve
• Difficult
to
measure
• High
inter-‐individual
variability
– Gene5cs
– Environment
/
culture
• Mood/anxiety
disorders
Opioids
• Single
most
effec5ve
medica5on
for
moderate-‐
severe
pain
• High
addic5on
liability
• High
inter-‐individual
variability
– Pharmacogene5cs
– Cultural
/
environmental
– Socioeconomic
status
60. More
control
Less
control
Ability
to
downregulate
use
Addic5on
“Legi5mate”
use
“Chemical
coping”
Opioid
use
-‐
misuse
spectrum
4
C’s
1. Loss
of
control
2. Compulsive
use
3. Con5nued
use
despite
harm
4. Craving
63. MAJOR
CONCERNS
OF
OPIOID
PRESCRIBERS
%
Poten5al
abuse
/
addic5on
89
%
Diversion
75
%
Opioid
side
effects
53
%
Regulatory
/
law
enforcement
monitoring
40
%
Hassle
and
5me
required
to
track/
refill
28
%
Upshur
CC
et
al.
J
Gen
Intern
Med
2006
64. “Red
Flags”
• “Urgency”
when
reques;ng
need
for
opioids
• Pa;ent
reports
side
effects
/
lack
of
efficacy
to
wide
variety
of
non-‐opioid
/
opioid-‐sparing
treatments
• Friday
arernoon
/
weekend
requests
for
medica;on
or
medica;on
changes
• Repeated
requests
for
the
following:
early
refill
dose
and/or
pill
volume
escala;on
above
requests
in
the
face
of
missed
follow
up
• Pa;ent
reports
lost
or
stolen
prescrip;on
65. “Red
Flags”
cont.
• Poor
correla;on
between
complaints,
physical
exam,
and/or
imaging
studies,
etc.
• “Inability”
or
refusal
to
provide
urine
sample
for
drug
screening
purposes
• Drug
screen
posi;ve
for
unreported
controlled
substances
and/or
illicit
drugs
67. The
Pain
Treatment
Environment
Elements
of
Discrimina;ng
Prescribing
Opioid
Rx
68. Elements
of
Discrimina;ng
Prescribing
Numerous
opioid
prescribing
guidelines
• medical
socie5es
/
organiza5ons;
states;
etc.
• No
single
defini5on
for
“best
prac5ces”
1. Thorough
Evalua5on
2. Prudent
Treatment
Plan
3. Vigilant
Follow
Up
69. Overview
of
Prescribers
All
other
prescribers
More
discrimina;ng
Less
discrimina;ng
The
“Pill
Mill”
Prescriber
70. Common“Pill
Mill”
Characteris;cs
• Nearly
exclusive
associa;ons
with
specific
pharmacies
• Physicians
with
minimal
or
no
training
in
pain
medicine
• Cash-‐based
payment
• Large
volume
of
pa;ents
seen
daily
(100
+)
• Unusually
large
volume
of
pa;ents
from
out
of
state
• Security
guards
on
site
• Non-‐tradi;onal
prac;ce
loca;on
–
e.g.
shopping
center
• Minimal
pa;ent
work-‐up
• Lihle
varia5on
in
choice
of
opioid
or
pill
volume
• Opioids
very
frequently
prescribed
simultaneously
with
benzodiazepines
and/or
carisoprodol
• High
dosages
/
high
pill
volumes
Sources:
DEA;
NADDI
71. The
University
of
Wisconsin
School
of
Medicine
and
Public
Health’s
Pain
and
Policy
Studies
Group
(PPSG)
awarded
Georgia
a
grade
of
“A”
for
its
pain
management
policies
in
2012,
marking
the
largest
improvement
in
the
na;on
from
2006
to
2012.
72. 1. How
definable
is
the
source
of
pain?
2. Screen
for
risk
of
addic;on
3. Explore
all
treatment
op;ons
4. If
opioids
are
prescribed:
lowest
effec;ve
dose
lowest
number
of
pills
5. Educate
the
pa;ent
risks/benefits
of
opioid
use
i. sharing
opioid
medica;ons
is
ILLEGAL
ii. proper
storage
and
disposal
6. Monitor
the
pa;ent
for
misuse
/
diversion
i. controlled
substances
agreement
ii. drug
screening
/
pill
counts
iii. PDMP
6
Point
Checklist
to
More
Discrimina;ng
Prescribing
73. The
Inescapable
Slippery
Slope
• Defining
that
which
does
not
have
a
single
defini;on:
– “pain”
– “valid”;
“legi;mate”
– “red
flags”
– “best
prac;ces”