what our clients need to know about i-stop

Report
NY State I-STOP Program
Mandatory on August 27, 2013 and Thereafter
WHAT IS I-STOP?
 I-STOP is also known as the Prescription Monitoring
Program (PMP) Registry, formally known as CSI
 I-STOP was developed through the offices of the New
York State Attorney General and was passed by the
State Legislature and signed by Governor Cuomo in
order to “exponentially enhance the effectiveness of
New York’s existing PMP to increase detection of
prescription fraud and drug diversion.”
WHAT IS THE PURPOSE BEHIND I-STOP?
 There were a reported
1,818 drug-related deaths
in the U.S. in 2008.
 For opioids (prescription
pain medication and
heroin) there were 9,135
emergency department
visits and 21,202 hospital
admissions reported for
2008 in the US.
SO THE PURPOSE OF I-STOP IS TO
PREVENT…?
 To prevent death, overdose and problems related to
the inappropriate use of these opioid type
medications!
 Even the most careful prescribers cannot prevent
someone from taking a whole bottle of pills if their
girlfriend leaves them, or of having their pills stolen
and sold on the street, or even from drinking alcohol
while taking them.
STREET VALUE!
 Many controlled substances are
cheap to buy, but command a
high street value!
 Hydrocodone, Oxycontin and
even drugs for ADHD are sold,
purchased, used and abused
regularly!
SAFE PRESCRIBING CANNOT STOP ALL
MISUSE
But the new rules are meant to help!
Some rules went into effect in
February of 2013 which required
patients to present to the prescribing
provider monthly for a new refill on
certain pain, muscle relaxant and
other type medications – multiple
refills cannot be given!
THE RULES AND REGULATIONS
I-STOP DETAILS
WHAT EXACTLY DOES I-STOP DO?
 The Internet System for Tracking Over-Prescribing Act, (I-STOP),
establishes an on-line, real-time, controlled substance reporting
system that requires prescribers to consult the prescription
monitoring registry prior to prescribing or dispensing Schedule
II,III or IV Controlled Substances.
 In addition, pharmacists, who did not previously have access to
the registry, as a result of I-STOP will NOW have access to the
registry in order to review the controlled substance history of an
individual for whom one or more prescriptions for controlled
substances are presented to the pharmacist.
THE REQUIREMENTS OF I-STOP


Requires the Department of
Health to establish and
maintain an on-line, realtime controlled substance
reporting system to track
the prescription and
dispensing of controlled
substances;
Requires providers to
review a patient’s
controlled substance
prescription history on the
system prior to prescribing;

NOTE: A provider may authorize a
support staff member to consult
the registry on his or her behalf,
provided that the provider takes
reasonable steps to ensure that
the staff member is sufficiently
competent to use the registry, and
the provider remains ultimately
responsible to ensure that the
registry is used for authorized
purposes and is used in a manner
that protects the confidentiality
of the information obtained from
the registry;
THE I-STOP VERBIAGE IS CONFUSING


CAREFUL… In one area the
law says…”A practitioner is
not required to consult the
registry prior to dispensing a
controlled substance,
provided that all other
requirements pertaining to
dispensing controlled
substances are followed”;
But the law also says you are
required to consult the
registry prior to prescribing a
controlled substances.
THE DIFFERENCE IS IN THE
WORDING AS MOST PROVIDERS
ARE NOT DISPENSING IN THEIR
OFFICES!


There are a number of exceptions
whereby the duty to consult the registry
does not apply, such as (A) it is not
reasonably possible to access the
registry in a timely manner; (B) no other
practitioner or designee who is
authorized to access the registry is
reasonably available; and (C) the
quantity of the controlled substance
prescribed does not exceed a 5 day
supply (regulations of the NYS DOH will
provide more specific information
regarding the exceptions); and
The duty to consult the registry does
not apply to Schedule V Controlled
Substances.
WHAT PROVIDERS NEED TO DO
RIGHT NOW!
 Providers practicing in NY State are required to
comply with I-STOP and that requires that they must
first have an active “Health Commerce Account” with
The State of New York, Department of Health’s Health
Commerce System.
 Providers seeking to establish such an account must
go to:
https://hcsteamwork1.health.state.ny.us/pub/top.html
PENALTIES FOR NOT USING I-STOP
 Of significant note, the duty for providers to comply is
strict and mandatory, carrying severe potential penalties
for any failure to comply, including but not limited to,
loss of license, civil penalties and/or
criminal charges.
 To avoid the possibility of such dire
events, plans for compliance with
I-STOP must be built, implemented
and adhered to immediately, and
without fail, by every provider
throughout New York.
SO THIS IS NY STATE TELLING ME
HOW TO PRESCRIBE?
 Not really, but few people realize that Hydrocodone has
become the most prescribed medication nationwide, even
topping blood pressure medications such as lisinopril, and
cholesterol lowering medications such as simvastatin, AND;
 When one considers the risks of Hydrocodone and similar
drugs; it simply makes sense to provide one more tool to
providers to insure the drugs are prescribed safely, and that
misuse can be tracked and stopped.
WHAT ABOUT PATIENTS WITH A REAL NEED TO
CONTROLLED SUBSTANCES?
 With I-STOP providing:
 The ability to track the use of these medicines;
 The ability to have providers use their support staff to review the IStop site;
 With more providers insuring:
 The proper use of lower level pain medications first (e.g. high dose
Ibuprofen) and therapies such as physical therapy, RICE, etc.;
 The amount prescribed is lower and the number given is fewer;
 By educating the public…
THESE MEDICATIONS WILL STILL BE AVAILABLE WHEN NEEDED
THE FEW EXCEPTIONS TO CONSULTING ISTOP
 When dispensing methadone
 Dispensing and administration of the controlled substance
in the prescriber’s office
 For medications administered in a hospital, nursing home
or hospice setting
 Written in an Emergency Department for a supply no
greater than 5 days
 When a provider cannot access the system through no fault
of his/her own, they can prescribe up to 5 days supply
 Instances where consulting the system would result in
delay in treating a patient
E-PRESCRIBING CONTROLLED
SUBSTANCES
E-Prescribing of
controlled
substances will be
NOT BE available in
N.Y. State UNTIL
January 2015.
ESTABLISHING AND MAINTAINING
AN HCS ACCOUNT
The Rules of the Road!
HOW TO ESTABLISH AN HCS ACCOUNT
 If you are a licensed professional, the application to establish an
account is available on the following website:
https://hcsteamwork1.health.state.ny.us/pub/top.html
 If you will be using unlicensed staff as your designee, they will first
have to obtain an HCA account with approval of your HCS
Coordinator (which may be a lead provider in the practice)
 Once the unlicensed professional or administrative staff acting as
a designee has an HCS account, the prescribing provider must log
into the HCS system: https://commerce.health.state.ny.us click on Coord
Account Tools under My Applications, Under Account Request,
Click “User” and follow the process
I SUBMITTED FOR AN HCS ACCOUNT, WHAT
NOW?
 New accounts are usually established within two
weeks. Once your application is processed you will be
emailed documents.
They must be printed, notarized and received by the
DOH for your user ID to be issued. For account
information or help with your HCS Account, please
contact Commerce Account Management (CAMU) at
1-866-529-1890, option 1.
I CURRENLY HAVE AN HCS ACCOUNT
– DO I HAVE TO REGISTER AGAIN?
 NO! But if you have not used the account within the
last 30 days, and every 30 days thereafter, you will
have to reset your password.
For expired passwords, forgotten user names, lost PIN…
call the number below!
For account information or to help with your HCS account, please
contact CAMU at 1-866-529-1890
I HAVE AN HCS ACCOUNT, HOW DO I CONSULT
THE I-STOP (PMP) REGISTRY?
 Go the HCS at: https://commerce.health.state.ny.us
 Log into the system with your user ID and password
 Click on the NYS PMP Registry campaign button on the
home page or select “Applications” at the top of the page.
Click the letter “P”
 If you do the latter, scroll down to “Prescription Monitoring
Program Registry”
 Click the green plus (+) sign under the Add/Remove column
to add this application to your favorites
 Click to open program
 Enter patient and other required information
ARE PRESCRIBERS REQUIRED TO REVIEW THE I-STOP (PMP) FOR
ANY CONTROLLED SUBSTANCE PRESCRIBED OR IS THE REVIEW
LIMITED TO CERTAIN DRUGS?
Effective August 27, 2013, the duty to consult the
PMP is required of the practitioner prior to
prescribing any controlled substance listed on
schedule II, II or IV.
CAN I SHARE THE REPORT WITH MY
PATIENT?
 Yes. Release of the information to your
patient is allowed but should be
based on your professional medical
judgment.
 All state and federal confidentiality laws should be
adhered to
WHAT TYPE OF INFORMATION DOE STHE
I-STOP REPORT PROVIDE?
Patient search reports will include all controlled
substances that were dispensed and reported by the
pharmacy or dispenser for the past 6 months.
Pharmacy and prescriber information will be
provided as well.
ARE REFILLS AND PARTIAL FILL REQUESTS
REPORTED AS WELL?
Yes. Dispensers are required to report
refills and partial-filled prescriptions to
the DOH through the PMP system.
DO I HAVE TO REPORT TO DOH THAT I HAVE REVIEWED
THE PATIENT’S PMP HISTORY?
 NO! But log-ins are tracked and can be used for or against a provider
when necessary
 Make it your practice protocol to document that you checked the registry (or if your
designee checks it, he/she should document that and you reference it), OR, why is
wasn’t checked (e.g. the FIOS cable to your practice had been cut)
 AND WHEN SOMETHING SUSPICIOUS SHOWS UP, OR YOU SUSPECT DIVERSION,
DOCTOR SHOPPING, ETC – you will note a link on the bottom of the confidential drug
utilization report to report a prescription discrepancy, or to send questions or
comments about the report to the Bureau of Narcotic Enforcement office.
IF I CHOOSE TO USE A DESIGNEE, HOW
DO I KNOW IF THERE IS A CONCERN?
 We strongly recommend that either you as the provider or your designee
note in the medical record that the PMP was checked for any patient
currently on controlled substances or for whom you will be prescribing.
 If the report shows a great deal of controlled substances having been filled
on this patient, or a lot of providers prescribing, we suggest that you have
your designee print the report and provide it to you as the provider
directly, while documenting “PMP reviewed, report printed and to
provider”, after which the provider should note what, if any action they
took based on the report.
MY PATIENT APPEARS ON THE I-STOP PMP, DOES THI SMEAN
HE/SHE IS A DOCTOR SHOPPER?
 Not necessarily. A PMP registry report indicates that your patient
has received controlled substance prescriptions in the last 6
months.
 The intent is to provide you with access 24/7 to your patient’s
controlled substance history to guide you in making your
treatment decisions.
 You are still in charge of your prescribing patterns.
WHAT IF MY PATIENT REPORTS DRUG OR IDENTITY THEFT?
 Refer the patient to the local police department in the
jurisdiction in which the event occurred.
 Upon receipt of a police report, use your best judgment in
writing with any controlled substance prescriptions,
document in the I-STOP PMP is you feel the need to do so,
and DEFINITLY document your decision-making rationale
regarding prescribing or not prescribing in the Medical
Record.
WHO DO I CONTACT IF I SEE A PRESCRIPTION
APPEARING ON THE I-STOP PMP AS HAVING BEEN
WRITTEN BY ME, BUT WHICH I DID NOT WRITE?
 Use the link on the page to report a prescription error to the
Bureau of Narcotic Enforcement.
 The link is located below your patient’s
prescription information.

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