OIG Reviews of States’ Oversight of Opioids
In a series of reviews, the OIG is studying the oversight that certain states are providing regarding opioid prescribing and monitoring of opioid use. They have completed these reviews for the state of Washington, Nevada, Utah, Nebraska, Tennessee, and New Hampshire. Two more states are upcoming. They include Texas and West Virginia. As the fact sheet for the New Hampshire review was most recently published, let’s look at what the OIG is reviewing and finding.
The OIG is asking select states to respond to a questionnaire covering the following five categories:
- Policies and Procedures
- Data Analytics
The resulting “fact sheet” for New Hampshire was 15 pages long, but they also offer a one-page summary. Some of the items that caught my attention were:
Prescription Drug Monitoring Program, or PDMP, is a web-based data system that contains information on controlled prescription medications dispensed by New Hampshire licensed retail pharmacies and other dispensers. The program monitors controlled drug prescriptions (U.S. Drug Enforcement Administration (DEA) Schedules II through IV) and provides New Hampshire licensed prescribers and dispensers a valuable tool to:
- Improve clinical decision making and patient care in managing their health and prescriptions
- Promote public health and safety through the prevention and treatment for misuse of controlled substances and assist in the reduction of the diversion of controlled substances.
New Hampshire uses its PDMP to collect data on controlled prescriptions (schedule II, III, and IV) dispensed in the State and that data is made available to practitioners (prescribers and dispensers) to review to assess and assist in managing the care of their patients.
- There is a requirement for prescribers to check the PDMP prior to prescribing a schedule II, III, or IV opioids for the treatment and management of pain.
- Prescribers (e.g., physicians, physician assistants, and dentists) and dispensers (e.g., pharmacist or prescriber delegates) have direct access to the PDMP.
- Regulatory boards, law enforcement with a court order, and patients have indirect access to the data (must request the information).
- DHHS does not have access to the PDMP data.
The Board of Medicine requires that DEA licensed prescribers to register with the PDMP and are required to complete 3 contact hours every 2 years of free regulatory-board approved online continuing education or pass an online application in the areas of pain management and addiction disorders. Based on recommendations in a performance audit report, New Hampshire is making improvements to the PDMP. For example, the audit report recommended developing criteria for reviewing PDMP data, reporting matters for further investigation, and notifying practitioners of concerns.
New Hampshire performs data analysis related to opioid prescribing and monitoring of opioid use (e.g., analyzing data to determine the number of opioid prescriptions written by providers to detect high-prescribing providers). Those efforts include the following:
- DHHS has periodically analyzed opioid prescribing in the Medicaid FFS and the Medicaid MCO populations.
- DHHS analysis has focused on member use rates by drug, strength (daily MME dose), supply (days in prescription and annual), and frequency of prescriptions (number in a year), and demographics (a type of Medicaid and poverty level).
- Provider-based reporting has been performed on a pilot basis. DHHS collects relevant Healthcare Effectiveness Data and Information Set (HEDIS) measures from its Medicaid MCOs.
- DHHS will use Federal opioid response funding to enhance its data reporting. Specifically, it will be using the State Opioid Response grant to increase data reporting to SAMHSA and will be using CDC opioid funding to integrate data and develop analytic dashboards.
The Office of Quality Assurance and Improvement (OQAI) is responsible for data analytics. They are doing the following:
- OQAI performs analysis of Medicaid claims data and Medicaid MCO submitted data.
- DHHS uses data analytics to monitor policy implementations.
- Action taken related to the pharmacies, providers, or beneficiaries identified because of the data analytics is used to identify the impact of prior authorization policy changes.
Lastly, in 2017, the Opioid Task Force completed a process identifying and prioritizing potential action strategies to reduce opioid-related harm in New Hampshire. There are many more items in the fact sheets for New Hampshire. You might also be interested in the findings of the other states. If you are interested, visit the OIG’s interactive map.