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March 23, 2022

Access to the Report to Congress: State Challenges and Best Practices Implementing PDMP Requirements Under Section 5042 of the SUPPORT Act published June 30, 2021.

The following excerpt from the report provides context and background.

Executive Summary

Background 

The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act was signed into law (Pub. L. No. 115-271) on October 24, 2018, as a bipartisan effort to address the nation’s opioid epidemic. 

Section 5042(a) of the SUPPORT Act requires all States to establish a qualified prescription drug monitoring program (PDMP). A PDMP ensures that providers have access to information about current and previous opioid prescriptions and other controlled substances at the time of an encounter. However, PDMP access is only the first step in addressing the opioid overdose epidemic. PDMP use must be part of a comprehensive approach that considers potential, unintended consequences. 

Beginning in October 2021, all State PDMPs must meet the requirements outlined in the legislation. The SUPPORT Act also authorizes the Centers for Medicare and & Medicaid Services (CMS) to match State investments in their PDMP at 100 percent for approved design, development, and implementation activities, for quarters during fiscal years 2019 and 2020. 

Further, section 5042(b) of the SUPPORT Act directs the Administrator of CMS, in collaboration with the Director of the Centers for Disease Control and Prevention (CDC), to generate a report describing best practices on the use of PDMPs and on protecting the privacy of model practices to protect Medicaid beneficiary information maintained in and accessed through prescription drug monitoring programs. Section 5042(c) of the SUPPORT Act also requires the Secretary to develop and publish model practices to assist State Medicaid program operations in identifying and implementing strategies to utilize PDMPs- agreements. State efforts to coordinate care between Medicaid and PDMPs is very nascent, limiting our ability to confidently highlight best practices. However, we do describe promising initiatives that states have enacted which have been informed by published recommendations. 

This report satisfies the requirements of section 5042(b) and (c) of the SUPPORT Act to the extent that such data is available to support the best practices and information provided therein. This report is divided into seven complementary sections: (1) PDMP variation across the States; (2) State activities funded through the Federal match authorized by the SUPPORT Act, (3) PDMP-related challenges cited by several States, (4) effective uses of the PDMP to improve patient safety, (5) examples of innovative uses of the PDMP, (6) feedback on the benefits and limitations of the PDMP shared by key stakeholders; and (7) lessons learned for State and Federal legislators to support and advance State PDMP investments. 

How States Have Used The 100% Federal Match 

The SUPPORT Act offered States a 100 percent Federal match of Medicaid dollars for approved investments to accelerate the establishment or augmentation of a qualified PDMP. A total of 14 States and one territory applied and were approved for the Federal match to fund the integration or enhancement of their State’s Medicaid information system and the State PDMP. Approvals occurred on a rolling basis between summer 2019 and summer 2020. Across the 15 States approved for the enhanced Federal match, the median funding request was $6 million reflecting a large volume of smaller (less than $10 million) requests. The value of approved Advance Planning Documents (APDs) for the States totaled $170,669,792 and ranged from just under $1.5 million (New Jersey) to $51 million (Nebraska). 

The SUPPORT Act offered States a 100 percent Federal match of Medicaid dollars for approved investments to accelerate the establishment or augmentation of a qualified PDMP. A total of 14 States and one territory applied and were approved for the Federal match to fund the integration or enhancement of their State’s Medicaid information system and the State PDMP. Approvals occurred on a rolling basis between summer 2019 and summer 2020. Across the 15 States approved for the enhanced Federal match, the median funding request was $6 million reflecting a large volume of smaller (less than $10 million) requests. The value of approved Advance Planning Documents (APDs) for the States totaled $170,669,792 and ranged from just under $1.5 million (New Jersey) to $51 million (Nebraska). 

An analysis of the approved State APDs revealed commonalities in State plans. Proposed uses for funding were categorized into four key domains: (1) Planning; (2) System Integration; (3) Infrastructure Development; and (4) Enhancements, Data, and Analytics. 

Lessons Learned 

Discussions with States and key stakeholders highlighted the following lessons learned and areas in which legislative changes at the Federal or State level could facilitate State PDMP efforts: 

Extended Timeline for Expending Funds Approved for Federal Match – States suggested that the U.S. Congress consider extending the timeline in order to leverage the funding in a way that best support the PDMP enhancement initiatives, 

National Data Standards – Although States are collaborating to improve patient matching to support data exchange, it was noted that these collaborative efforts would benefit from Federal guidance on data content and exchange standards. 

Clarification of Requirements for a Qualified PDMP – Several States expressed confusion regarding how to interpret some of the language in the SUPPORT Act legislation, resulting in unanticipated issues related to tracking and enforcing compliance. 

Flexibility in Use of Federal Funds – Several Federal agencies have offered States PDMP funding, but each opportunity comes with restrictions, which have impeded the State from focusing on its State-specific priorities. 

Identification of State Legislation That Impedes PDMP Development and Use – Some State legislative mandates, including data privacy laws, have created barriers to effectively developing and implementing PDMPs. 

Improved Coordination with Federal PDMP Programs – Several Federal health programs operate their own PDMP, including the Department of Defense (DOD) and the Department of Veterans Affairs (VA). Data from State residents receiving services from these Federal programs may not be currently captured in the State PDMP. 

Comprehensive State Mandates – A number of States have enacted laws to encourage and promote greater use of the State PDMP. There should be more consistency across States that have enacted these policies and supporting policies in place to monitor compliance. 

Funding for State Collaboration – Collaboration with peer States has proven very effective in communicating best practices, leveraging limited resources, and increasing efficiencies. 

Increased Integration Between PDMP and EHRs – Improving the technical workflow to enable providers to check the PDMP through their electronic health record (EHR) system during the time of the patient encounter or before prescribing controlled substances has proven effective in increasing provider compliance with checking the PDMP. 

Best Practices on Increasing Enrollment and Use of PDMP – While some States have successfully enrolled many providers to use the PDMP, other States are experiencing 

challenges. The Federal government can help overcome these obstacles by conducting a case study that examines and highlights best practices for provider enrollment, collaborate with State medical boards, NPPES, State PDMPs, and credentialing offices to facilitate PDMP registration at the time of medical license renewal, and provide technical assistance for healthcare provider directory solutions. 

Enhanced Education and Training for Providers, Payers, and Patients – Improving education and training on how to effectively use the PDMP and its limitations can improve patient safety, clinical care, and coordination. 

Evaluation of Impact of PDMPs – Conduct formal analyses to identify best practices that can be adopted by other States while also confirming that the PDMP achieves its intended goals. 


Report to Congress: State Challenges and Best Practices Implementing PDMP Requirements Under Section 5042 of the SUPPORT Act , pages 1-2