Difference between revisions of "Expand & Enhance Prescription Drug Monitoring Program (PDMP)"

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Return to [[Opioid_Top-Level_Strategy_Map|Opioid Top-Level Strategy Map]]<span style="font-size: 13px;">or </span>[[ZOOM_MAP_-_Expand_&_Enhance_Prescription_Drug_Monitoring_Program|Zoom Map (Expand & Enhance PDMP)&nbsp;]]
=Expand & Enhance Prescription Drug Monitoring Program=
+
or [[Zoom_Map_-_Reduce_Access_to_Opioids|Zoom Map (Reduce Access to Opioids)]]<br/> or [[ZOOM_MAP_-_Minimize_Diversion_of_Prescription_Drugs|Zoom Map (Minimize Diversion of Prescription Drugs)]] <div id="toc">
Return to [[Opioid Top-Level Strategy Map]] or [[ZOOM%20MAP%20-%20Expand%20%26%20Enhance%20Prescription%20Drug%20Monitoring%20Program|Zoom Map (Expand & Enhance PDMP) ]]<br />  or [[Zoom Map - Reduce Access to Opioids|Zoom Map (Reduce Access to Opioids)]]<br /> or [[ZOOM MAP - Minimize Diversion of Prescription Drugs|Zoom Map (Minimize Diversion of Prescription Drugs)]]<br /> <div id="toc">
+
= Table of Contents =
=Table of Contents=
+
<div style="margin-left: 6em">&nbsp;</div> <div style="margin-left: 1em">[[#Purpose|Purpose]]</div> <div style="margin-left: 1em">[[#Impact|Impact]]</div> <div style="margin-left: 2em">[[#Impact-Positive|Positive]]</div> <div style="margin-left: 2em">[[#Impact-Negative|Negative]]</div> <div style="margin-left: 1em">[[#Legislation|Legislation]]</div> <div style="margin-left: 1em">[[#Funding_Opportunities|Funding Opportunities]]</div> <div style="margin-left: 2em">[[#Funding_Opportunities-Current_Funding_Methods|Current Funding Methods]]</div> <div style="margin-left: 2em">[[#Funding_Opportunities-Potential_Funding_Methods|Potential Funding Methods]]</div> <div style="margin-left: 1em">[[#Opportunities_to_Enhance_PDMPs|Opportunities to Enhance PDMPs]]</div> <div style="margin-left: 2em">[[#Opportunities_to_Enhance_PDMPs-TTAC|TTAC]]</div> <div style="margin-left: 2em">[[#Opportunities_to_Enhance_PDMPs-Third_Party_Patient_Monitoring|Third Party Patient Monitoring]]</div> <div style="margin-left: 2em">[[#Opportunities_to_Enhance_PDMPs-Provider_Challenges_to_Effective_Use_of_PDMPs|Provider Challenges to Effective Use of PDMPs]]</div> <div style="margin-left: 2em">[[#Opportunities_to_Enhance_PDMPs-Use_PDMPs_to_Improve_Patient_Safety|Use PDMPs to Improve Patient Safety]]</div> <div style="margin-left: 2em">[[#Opportunities_to_Enhance_PDMPs-National_Alliance_for_Model_State_Drug_Laws|National Alliance for Model State Drug Laws]]</div> <div style="margin-left: 1em">[[#State_PDMPs|State PDMPs]]</div> <div style="margin-left: 2em">[[#State_PDMPs-Find_Your_State.27s_PDMP|Find Your State's PDMP]]</div> <div style="margin-left: 1em">[[#Innovative_Use_of_PDMP_Data|Innovative Use of PDMP Data]]</div> <div style="margin-left: 2em">[[#Innovative_Use_of_PDMP_Data-Notify_the_Care_Team_that_Prescribed_the_Opioids_of_the_Overdose_Death|Notify the Care Team that Prescribed the Opioids of the Overdose Death]]</div> <div style="margin-left: 1em">[[#Tools_.26_Resources|Tools & Resources]]</div> <div style="margin-left: 1em">[[#Scorecard_Building|Scorecard Building]]</div> <div style="margin-left: 1em">[[#Resources_to_Investigate|Resources to Investigate]]</div> <div style="margin-left: 1em">[[#Sources|Sources]]</div> </div>  
<div style="margin-left: 6em">[[#toc0| ]]</div><div style="margin-left: 1em">[[#Purpose|Purpose]]</div><div style="margin-left: 1em">[[#Impact|Impact]]</div><div style="margin-left: 2em">[[#Impact-Positive|Positive]]</div><div style="margin-left: 2em">[[#Impact-Negative|Negative]]</div><div style="margin-left: 1em">[[#Legislation|Legislation]]</div><div style="margin-left: 1em">[[#Funding Opportunities|Funding Opportunities]]</div><div style="margin-left: 2em">[[#Funding Opportunities-Current Funding Methods|Current Funding Methods]]</div><div style="margin-left: 2em">[[#Funding Opportunities-Potential Funding Methods|Potential Funding Methods]]</div><div style="margin-left: 1em">[[#Opportunities to Enhance PDMPs|Opportunities to Enhance PDMPs]]</div><div style="margin-left: 2em">[[#Opportunities to Enhance PDMPs-TTAC|TTAC]]</div><div style="margin-left: 2em">[[#Opportunities to Enhance PDMPs-Third Party Patient Monitoring|Third Party Patient Monitoring]]</div><div style="margin-left: 2em">[[#Opportunities to Enhance PDMPs-Provider Challenges to Effective Use of PDMPs|Provider Challenges to Effective Use of PDMPs]]</div><div style="margin-left: 2em">[[#Opportunities to Enhance PDMPs-Use PDMPs to Improve Patient Safety|Use PDMPs to Improve Patient Safety]]</div><div style="margin-left: 2em">[[#Opportunities to Enhance PDMPs-National Alliance for Model State Drug Laws|National Alliance for Model State Drug Laws]]</div><div style="margin-left: 1em">[[#State PDMPs|State PDMPs]]</div><div style="margin-left: 2em">[[#State PDMPs-Find Your State's PDMP|Find Your State's PDMP]]</div><div style="margin-left: 1em">[[#Innovative Use of PDMP Data|Innovative Use of PDMP Data]]</div><div style="margin-left: 2em">[[#Innovative Use of PDMP Data-Notify the Care Team that Prescribed the Opioids of the Overdose Death|Notify the Care Team that Prescribed the Opioids of the Overdose Death]]</div><div style="margin-left: 1em">[[#Tools & Resources|Tools & Resources]]</div><div style="margin-left: 1em">[[#Scorecard Building|Scorecard Building]]</div><div style="margin-left: 1em">[[#Resources to Investigate|Resources to Investigate]]</div><div style="margin-left: 1em">[[#Sources|Sources]]</div></div>
+
====== &nbsp; ======
====== ======
 
=<span style="background-color: #ffffff">Purpose</span>=
 
[https://www.cdc.gov/drugoverdose/pdmp/ Prescription Drug Monitoring Programs ] (PDMP) allows pre-registered users including licensed healthcare prescribers eligible to prescribe controlled substances, pharmacists authorized to dispense controlled substances, law enforcement, and regulatory boards to access timely patient controlled substance history information.<sup class="reference">[1]</sup><br /> <br />  PDMPs are designed to collect, monitor, and analyze electronically transmitted prescribing and dispensing data submitted by pharmacies and dispensing practitioners. This information is used to assist prescribers, dispensers, and other health care professionals in making clinical decisions for their patients. PDMPs also have been shown to reduce adverse drug interactions, and help health care professionals identify patients who may be in need of substance use treatment. Law enforcement and regulatory/licensing board officials utilize PDMP information, under appropriate circumstances, to further their investigations of suspected violations of controlled substance laws and compliance with regulatory/licensing board practice standards. Many states have also begun to use PDMPs as a public health surveillance tool. PDMPs continue to be among the most promising state-level interventions to improve opioid prescribing, inform clinical practice, and protect patients at risk.<sup class="reference">[2]</sup><br /> <br />  The main objectives of these programs are to:<br />
 
  
* Improve patient safety.
+
= <span style="background-color: #ffffff">Purpose</span> =
* Build a data collection and analysis system at a state level.
 
* Enhance existing programs' ability to analyze and use collected data.
 
* Facilitate the exchange of collected prescription data among states.
 
* Assess the efficiency and effectiveness of the programs funded under this initiative.<sup class="reference">[3]</sup>
 
<br />  PDMPs can alert Healthcare Providers to provide potentially lifesaving information and interventions.<br />  
 
  
* They DO for those using prescription opioids
+
[https://www.cdc.gov/drugoverdose/pdmp/ Prescription Drug Monitoring Programs ] (PDMP) allows pre-registered users including licensed healthcare prescribers eligible to prescribe controlled substances, pharmacists authorized to dispense controlled substances, law enforcement, and regulatory boards to access timely patient controlled substance history information.<sup class="reference">[1]</sup><br/> <br/> PDMPs are designed to collect, monitor, and analyze electronically transmitted prescribing and dispensing data submitted by pharmacies and dispensing practitioners. This information is used to assist prescribers, dispensers, and other health care professionals in making clinical decisions for their patients. PDMPs also have been shown to reduce adverse drug interactions, and help health care professionals identify patients who may be in need of substance use treatment. Law enforcement and regulatory/licensing board officials utilize PDMP information, under appropriate circumstances, to further their investigations of suspected violations of controlled substance laws and compliance with regulatory/licensing board practice standards. Many states have also begun to use PDMPs as a public health surveillance tool. PDMPs continue to be among the most promising state-level interventions to improve opioid prescribing, inform clinical practice, and protect patients at risk.<sup class="reference">[2]</sup><br/> <br/> The main objectives of these programs are to:
** Help collaborate with the patient to taper to a safer dosage
 
** Consider offering naloxone
 
** Communicate with other providers managing the patient
 
** Weigh patient goals, needs, risks
 
* They DO for those who they consider to have opioid use disorder, discuss safety concerns and treatment options<sup class="reference">[4]</sup>
 
* They DO NOT dismiss patients from care
 
<br /> With this in mind, states are trying to find ways to increase use of PDMPs by prescribers so they avoid having a mandate. In some states, you are automatically registered when practitioners apply for a license. There are also efforts to integrate PDMP data into electronic medical record systems so the information is available at the point of care.<sup class="reference">[5]</sup><br /> <br />  
 
=Impact=
 
==Positive==
 
  
* Between the years of 2010-2012 Florida implemented a PDMP and other "pill mill" policies that had an positive impact on the opioid epidemic. According to the CDC, Florida recorded a 26.1% decrease in opioid analgesic overdose deaths, after these policies were implemented.<sup class="reference">[6]</sup> The Florida Department of Health said that from 2010 to 2013, oxycodone overdose deaths fell from 1,516 to 534—a 65% decrease.<sup class="reference">[7]</sup>
+
*Improve patient safety.  
* New York Experienced a 75% decrease in prescriptions issued through "doctor shopping" as a result of a 2012 requirement that prescribers check the PDMP before writing a prescription.<sup class="reference">[8]</sup>
+
*Build a data collection and analysis system at a state level.  
* 74% of California physicians reportedly changed their prescribing practice as a result of patient activity reports created using the state's PDMP<sup class="reference">[9]</sup>
+
*Enhance existing programs' ability to analyze and use collected data.  
* After establishing a PDMP, Tennessee saw a reduction in the morphine milligram equivalents dispensed, a reduction in the number of doctor and pharmacy shoppers going to multiple outlets to obtain drugs, an increase in queries to the State's Controlled Substance Monitoring Database Program by prescribers and extenders, and a change in practices, with some 41.4% less likely to prescribe certain controlled substances.<sup class="reference">[10]</sup>
+
*Facilitate the exchange of collected prescription data among states.  
<br />
+
*Assess the efficiency and effectiveness of the programs funded under this initiative.<sup class="reference">[3]</sup>  
==Negative==
 
The existence of a Prescription Drug Monitoring Program within a state, however, '''appears to increase drug diversion activities in contiguous non-PDMP states'''. When states begin to monitor drugs, drug diversion activities tend to spill across boundaries to non-PDMP states. One example is provided by Kentucky, which shares a boundary with seven states, only two of which have PDMPs -- Indiana and Illinois. As drug diverters became aware of Kentucky PDMP's ability to trace their drug histories, they tended to move their diversion activities to nearby nonmonitored states. OxyContin diversion problems have worsened in Tennessee, West Virginia, and Virginia -- all contiguous non-PDMP states -- because of the presence of Kentucky's PDMP, according to a joint federal, state, and local drug diversion report.<sup class="reference">[11]</sup><br /> <br />
 
=Legislation=
 
The Prescription Drug Monitoring Program was created by the FY 2002 U.S. Department of Justice Appropriations Act (Public Law 107-77). <sup class="reference">[12]</sup><br /> <br />
 
=Funding Opportunities=
 
==Current Funding Methods==
 
  
* Federal grants
+
<br/> PDMPs can alert Healthcare Providers to provide potentially lifesaving information and interventions.
* Private/Non-federal grants
 
* General revenue funds
 
* Controlled substance registration fees
 
* Professional licensing fees
 
* Regulatory board funds
 
==Potential Funding Methods==
 
  
* Legal settlements
+
*They DO for those using prescription opioids
* PDMP licensing fees
+
**Help collaborate with the patient to taper to a safer dosage
* Health insurance licensing fees
+
**Consider offering naloxone
* Private donations
+
**Communicate with other providers managing the patient
* Medicaid fraud settlements
+
**Weigh patient goals, needs, risks 
* Assessed fines
+
*They DO for those who they consider to have opioid use disorder, discuss safety concerns and treatment options<sup class="reference">[4]</sup>  
* Asset Forfeiture
+
*They DO NOT dismiss patients from care
* Drug manufacturers' assessment
 
* Prescription fees
 
* Private third party payers or health insurers
 
* PDMP authorized users <sup class="reference">[13]</sup>
 
*see the PDMP TTAC Funding Options for Prescription Drug Monitoring Programs in [[TR%20-%20Expand%20%26%20Enhance%20Prescription%20Drug%20Monitoring%20Programs|Tools and Resources ]]for full descriptions.<br /> <br /> <u>The Comprehensive Opioid Abuse Program Training and Technical Assistance (TTA) Program</u> is a grant from the U.S. Bureau of Justice given to state, local, and tribal governments to provide resources to intervene with persons with substance use disorders.<sup class="reference">[14]</sup> The goals of the Comprehensive Opioid Abuse TTA Program are twofold. First, the program aims to support site-based and state initiatives designed to reduce opioid misuse and the number of overdose fatalities. Second, the program supports PDMPs and their stakeholders in expanding the implementation, enhancement, and proactive use of prescription drug monitoring programs to support clinical decision-making and prevent the misuse and diversion of controlled substances. Proposals due April 25, 2017.<sup class="reference">[15]</sup><br /> <br />  The Comprehensive Opioid Abuse Site-based Program - Harold Rogers Prescription Drug Monitoring Program Implementation and Enhancement Projects<br />  Funding opportunity which provides state, local, and tribal governments resources to intervene with persons with substance use disorders.The Harold Rogers Prescription Drug Monitoring Program (PDMP) is being incorporated into the FY 2017 Comprehensive Opioid Abuse Site-based Program. The purpose of this program is to improve collaboration and strategic decision-making of regulatory and law enforcement agencies and public health officials to address prescription drug and opioid misuse, save lives, and reduce crime. This is made possible through the collection and analysis of controlled substance prescription data and other scheduled chemical products through a centralized database administered by an authorized state agency. This program will be applied by April 25, 2017.<sup class="reference">[16]</sup><br />  
 
=Opportunities to Enhance PDMPs=
 
==TTAC==
 
[http://www.pdmpassist.org/ Training Technical Assistance Center ]: Brandeis University, in partnership with the Bureau of Justice Assistance, has developed the PDMP TTAC to provide services, support, resources and strategies to improve the effectiveness of state PDMPs. Call 781-609-7741 for more information.<br />
 
==Third Party Patient Monitoring==
 
'''GuideMed Monitoring''' is a management program for prescription narcotics monitoring. It helps provider networks prevent prescription drug misuse and it helps to protect the network and its practitioners from liabilities associated with prescription narcotics.<sup class="reference">[17]</sup> Patient service stations are established on-site or freestanding in locations determined by the physician, where GuideMed nurses will staff and manage the monitoring activities chosen by the physician (Risk Assessments, PDMP Checks, CSA Reviews, Pill Counts, Toxicology Testing). After the nurse gathers all the necessary information, a report is prepared and sent to the patient's physician via a PDF file attached to that patient's record. GuideMed also provides any data needed for a compliance officer.<sup class="reference">[18]</sup><br />
 
==Provider Challenges to Effective Use of PDMPs==
 
  
* <u>Insufficient Resources:</u> Providers lack the time within their practice to perform all activities (not staffed sufficiently, not reimbursed, not value-added). Virtually every knowledge and use survey for PDMPs, for example, shows only half of physicians use the PDMP and the reasons cited for not using it are "it's too time consuming" and "its too difficult to use." ("I need to see a patient every 12 minutes to make ends meet, I do not have the time or capacity to do all of this work.")
+
<br/> With this in mind, states are trying to find ways to increase use of PDMPs by prescribers so they avoid having a mandate. In some states, you are automatically registered when practitioners apply for a license. There are also efforts to integrate PDMP data into electronic medical record systems so the information is available at the point of care.<sup class="reference">[5]</sup><br/> &nbsp;
* <u>Patient Provider Relationship:</u> The design of many programs tends to compromise the trust between patients and physicians because the providers are required to police their patients, and this is not something physicians see as part of their role as care providers. ("I did not go to medical school for this. I need a trusting relationship with the patient, which is not possible when I ask to count their pills.")
 
* <u>Data Management:</u> There is no automation support for any of this activity today, no field within the EMR to enter the risk-adjusted monitoring protocols or schedule patient activities according to risk levels, there is no place to store the results of a pill count or PDMP check or alert the physician when a treatment agreement needs to be updated.
 
* <u>Consistency:</u> Whether it is patients within a practice, practices within a network, or health systems within the state -- getting everyone to establish and adhere to protocols consistently is a challenge, yet inconsistent application of protocols is one of the greatest liabilities for any provider.<sup class="reference">[19]</sup>
 
<br /> '''Prescription Drug Monitoring Information Exchange (PMIX)''' Architecture enables nationwide information sharing by the use of free, open, and consensus-based solutions; a common formatting of shared data; security and privacy protocols to protect sensitive information; and preserving the state choice of interstate sharing solutions.<sup class="reference">[20]</sup><br />
 
==Use PDMPs to Improve Patient Safety==
 
==National Alliance for Model State Drug Laws==
 
View [http://www.namsdl.org/prescription-monitoring-programs.cfm model PDMP laws ] and documents from states with prescription drug monitoring programs<br />
 
  
* Annual summaries or highlights
+
= Impact =
* Administration of PDMPs
+
 
* Data Reporting and Retention
+
== Positive ==
* Types of Authorized Recipients
+
 
* Access and Registration
+
*Between the years of 2010-2012 Florida implemented a PDMP and other "pill mill" policies that had an positive impact on the opioid epidemic. According to the CDC, Florida recorded a 26.1% decrease in opioid analgesic overdose deaths, after these policies were implemented.<sup class="reference">[6]</sup> The Florida Department of Health said that from 2010 to 2013, oxycodone overdose deaths fell from 1,516 to 534—a 65% decrease.<sup class="reference">[7]</sup>
* PDMPs and Privacy
+
*New York Experienced a 75% decrease in prescriptions issued through "doctor shopping" as a result of a 2012 requirement that prescribers check the PDMP before writing a prescription.<sup class="reference">[8]</sup>
* Miscellaneaous Documents
+
*74% of California physicians reportedly changed their prescribing practice as a result of patient activity reports created using the state's PDMP<sup class="reference">[9]</sup>
=State PDMPs=
+
*After establishing a PDMP, Tennessee saw a reduction in the morphine milligram equivalents dispensed, a reduction in the number of doctor and pharmacy shoppers going to multiple outlets to obtain drugs, an increase in queries to the State's Controlled Substance Monitoring Database Program by prescribers and extenders, and a change in practices, with some 41.4% less likely to prescribe certain controlled substances.<sup class="reference">[10]</sup>
 +
 
 +
&nbsp;
 +
 
 +
== Negative ==
 +
 
 +
The existence of a Prescription Drug Monitoring Program within a state, however, '''appears to increase drug diversion activities in contiguous non-PDMP states'''. When states begin to monitor drugs, drug diversion activities tend to spill across boundaries to non-PDMP states. One example is provided by Kentucky, which shares a boundary with seven states, only two of which have PDMPs -- Indiana and Illinois. As drug diverters became aware of Kentucky PDMP's ability to trace their drug histories, they tended to move their diversion activities to nearby nonmonitored states. OxyContin diversion problems have worsened in Tennessee, West Virginia, and Virginia -- all contiguous non-PDMP states -- because of the presence of Kentucky's PDMP, according to a joint federal, state, and local drug diversion report.<sup class="reference">[11]</sup>
 +
 
 +
 
 +
 
 +
= Legislation =
 +
 
 +
The Prescription Drug Monitoring Program was created by the FY 2002 U.S. Department of Justice Appropriations Act (Public Law 107-77). <sup class="reference">[12]</sup>
 +
 
 +
 
 +
 
 +
= Funding Opportunities =
 +
 
 +
== Current Funding Methods ==
 +
 
 +
*Federal grants
 +
*Private/Non-federal grants
 +
*General revenue funds
 +
*Controlled substance registration fees
 +
*Professional licensing fees
 +
*Regulatory board funds
 +
 
 +
== Potential Funding Methods ==
 +
 
 +
*Legal settlements
 +
*PDMP licensing fees
 +
*Health insurance licensing fees
 +
*Private donations
 +
*Medicaid fraud settlements
 +
*Assessed fines
 +
*Asset Forfeiture
 +
*Drug manufacturers' assessment
 +
*Prescription fees
 +
*Private third party payers or health insurers
 +
*PDMP authorized users <sup class="reference">[13]</sup>
 +
*see the PDMP TTAC Funding Options for Prescription Drug Monitoring Programs in [[TR_-_Expand_&_Enhance_Prescription_Drug_Monitoring_Programs|Tools and Resources for]] full descriptions.<br/> <br/> <u>The Comprehensive Opioid Abuse Program Training and Technical Assistance (TTA) Program</u> is a grant from the U.S. Bureau of Justice given to state, local, and tribal governments to provide resources to intervene with persons with substance use disorders.<sup class="reference">[14]</sup> The goals of the Comprehensive Opioid Abuse TTA Program are twofold. First, the program aims to support site-based and state initiatives designed to reduce opioid misuse and the number of overdose fatalities. Second, the program supports PDMPs and their stakeholders in expanding the implementation, enhancement, and proactive use of prescription drug monitoring programs to support clinical decision-making and prevent the misuse and diversion of controlled substances. Proposals due April 25, 2017.<sup class="reference">[15]</sup><br/> <br/> The Comprehensive Opioid Abuse Site-based Program - Harold Rogers Prescription Drug Monitoring Program Implementation and Enhancement Projects<br/> Funding opportunity which provides state, local, and tribal governments resources to intervene with persons with substance use disorders.The Harold Rogers Prescription Drug Monitoring Program (PDMP) is being incorporated into the FY 2017 Comprehensive Opioid Abuse Site-based Program. The purpose of this program is to improve collaboration and strategic decision-making of regulatory and law enforcement agencies and public health officials to address prescription drug and opioid misuse, save lives, and reduce crime. This is made possible through the collection and analysis of controlled substance prescription data and other scheduled chemical products through a centralized database administered by an authorized state agency. This program will be applied by April 25, 2017.<sup class="reference">[16]</sup>
 +
 
 +
= Opportunities to Enhance PDMPs =
 +
 
 +
== TTAC ==
 +
 
 +
[http://www.pdmpassist.org/ Training Technical Assistance Center ]: Brandeis University, in partnership with the Bureau of Justice Assistance, has developed the PDMP TTAC to provide services, support, resources and strategies to improve the effectiveness of state PDMPs. Call 781-609-7741 for more information.
 +
 
 +
== Third Party Patient Monitoring ==
 +
 
 +
'''GuideMed Monitoring''' is a management program for prescription narcotics monitoring. It helps provider networks prevent prescription drug misuse and it helps to protect the network and its practitioners from liabilities associated with prescription narcotics.<sup class="reference">[17]</sup> Patient service stations are established on-site or freestanding in locations determined by the physician, where GuideMed nurses will staff and manage the monitoring activities chosen by the physician (Risk Assessments, PDMP Checks, CSA Reviews, Pill Counts, Toxicology Testing). After the nurse gathers all the necessary information, a report is prepared and sent to the patient's physician via a PDF file attached to that patient's record. GuideMed also provides any data needed for a compliance officer.<sup class="reference">[18]</sup>
 +
 
 +
== Provider Challenges to Effective Use of PDMPs ==
 +
 
 +
*<u>Insufficient Resources:</u> Providers lack the time within their practice to perform all activities (not staffed sufficiently, not reimbursed, not value-added). Virtually every knowledge and use survey for PDMPs, for example, shows only half of physicians use the PDMP and the reasons cited for not using it are "it's too time consuming" and "its too difficult to use." ("I need to see a patient every 12 minutes to make ends meet, I do not have the time or capacity to do all of this work.")
 +
*<u>Patient Provider Relationship:</u> The design of many programs tends to compromise the trust between patients and physicians because the providers are required to police their patients, and this is not something physicians see as part of their role as care providers. ("I did not go to medical school for this. I need a trusting relationship with the patient, which is not possible when I ask to count their pills.")
 +
*<u>Data Management:</u> There is no automation support for any of this activity today, no field within the EMR to enter the risk-adjusted monitoring protocols or schedule patient activities according to risk levels, there is no place to store the results of a pill count or PDMP check or alert the physician when a treatment agreement needs to be updated.
 +
*<u>Consistency:</u> Whether it is patients within a practice, practices within a network, or health systems within the state -- getting everyone to establish and adhere to protocols consistently is a challenge, yet inconsistent application of protocols is one of the greatest liabilities for any provider.<sup class="reference">[19]</sup>
 +
 
 +
<br/> '''Prescription Drug Monitoring Information Exchange (PMIX)''' Architecture enables nationwide information sharing by the use of free, open, and consensus-based solutions; a common formatting of shared data; security and privacy protocols to protect sensitive information; and preserving the state choice of interstate sharing solutions.<sup class="reference">[20]</sup>
 +
 
 +
== Use PDMPs to Improve Patient Safety ==
 +
 
 +
== National Alliance for Model State Drug Laws ==
 +
 
 +
View [http://www.namsdl.org/prescription-monitoring-programs.cfm model PDMP laws ] and documents from states with prescription drug monitoring programs
 +
 
 +
 
 +
*Annual summaries or highlights  
 +
*Administration of PDMPs  
 +
*Data Reporting and Retention  
 +
*Types of Authorized Recipients  
 +
*Access and Registration  
 +
*PDMPs and Privacy  
 +
*Miscellaneaous Documents  
 +
 
 +
= State PDMPs =
 +
 
 +
#<span style="background-color: #ffffff">[https://oag.ca.gov/cures CURES ]: California's state PDMP. Learn more at [https://oag.ca.gov/cures/faqs CURES FAQs]</span>
 +
#<span style="background-color: #ffffff">[http://www.orhealthleadershipcouncil.org/our-current-initiatives/emergency-department-information-exchange-edie EDIE ]: Oregon and Washington use the Emergency Department Information Exchange (EDIE) system. This technology allows ED practicioners to identify patients with more than 5 ER visits in a one year period or those with complex care needs who can be directed to appropriate care. This system allows for alerts to hospitals as soon as patient visits ER.</span>
 +
#<span style="background-color: #ffffff">[http://www.floridahealth.gov/statistics-and-data/e-forcse/ EFORSCE ]: Florida's PDMP. This database has been in effect since 2010 and there are [http://www.floridahealth.gov/statistics-and-data/e-forcse/news-reports/index.html annual reports ] for each year. The website also includes a list of it's [http://www.floridahealth.gov/statistics-and-data/e-forcse/funding/index.html funding sources ].</span>
 +
#<span style="background-color: #ffffff">[https://pharmacypmp.az.gov/ Arizona State Board of Pharmacy Controlled Substances Prescription Monitoring Program (CSPMP) ]- Allows practitioners and pharmacists to look up, view, and print controlled substance dispensing information on their specific patients directly via user name and password.</span>
 +
#<span style="color: #fa1048">[http://www.worxpdmp.com/ WORx]</span><span style="background-color: #ffffff">Wyoming's active PDMP system.</span>
 +
 
 +
&nbsp;
 +
 
 +
== Find Your State's PDMP ==
 +
 
 +
Use this [http://mytopcare.org/resources/using-the-state-prescription-monitoring-program-pmp-effectively/find-your-states-pmp/ link] to find your state's Prescription Drug Monitoring Program.
 +
 
 +
 
 +
 
 +
= Innovative Use of PDMP Data =
 +
 
 +
== Notify the Care Team that Prescribed the Opioids of the Overdose Death ==
 +
 
 +
In Monterey County, CA, Coroners who identify that a person has died after misusing prescription opioids make use of data in the PDMP to identify and notify the care team that prescribed the opioids that their patient died. This seems to have had a big impact on prescribers and seems to have contributed to significant reductions in opioid prescription rates and increased use of non-opioid treatments for pain. (Need details and source.)
 +
 
 +
 
 +
= Tools & Resources =
 +
 
 +
[[TR_-_Expand_&_Enhance_Prescription_Drug_Monitoring_Programs|TR - Expand & Enhance Prescription Drug Monitoring Programs]]<br/> <br/> The Pew Charitable Trust created a report on [http://www.pewtrusts.org/en/research-and-analysis/reports/2016/12/prescription-drug-monitoring-programs Evidence-Based Practices to Optimize Use of PDMPs]
 +
 
 +
= Scorecard Building =
 +
 
 +
[[PO_-_Expand_&_Enhance_Prescription_Drug_Monitoring_Progams|Potential Objective Details]]<br/> [[PM_-_Expand_&_Enhance_Prescription_Drug_Monitoring_Program|Potential Measures & Data Sources]]<br/> [[PA_-_Expand_and_Enhance_Prescription_Drug_Monitoring_Program|Potential Actions & Partners]]
 +
 
 +
= Resources to Investigate =
 +
 
 +
[[More_Resources_to_Investigate_on_PDMP_use_and_impact|More Resources to Investigate on PDMP Use and Impact]]<br/> <br/> <span style="background-color: #ffffff; color: #222222; font-family: arial,sans-serif; font-size: 12.8px">'''<span style="color: #4d4d4d">PAGE MANAGER</span>:''' </span><span style="background-color: #ffffff; color: #ff0000; font-family: arial,sans-serif; font-size: 12.8px">[insert name here]</span><br/> <span style="background-color: #ffffff; color: #222222; font-family: arial,sans-serif; font-size: 12.8px">'''<span style="color: #4d4d4d">SUBJECT MATTER EXPERT</span>''': </span><span style="background-color: #ffffff; color: #ff0000; font-family: arial,sans-serif; font-size: 12.8px">[fill out table below]</span>
  
# <span style="background-color: #ffffff">[https://oag.ca.gov/cures CURES ]: California's state PDMP. Learn more at [https://oag.ca.gov/cures/faqs CURES FAQs]</span>
 
# <span style="background-color: #ffffff">[http://www.orhealthleadershipcouncil.org/our-current-initiatives/emergency-department-information-exchange-edie EDIE ]: Oregon and Washington use the Emergency Department Information Exchange (EDIE) system. This technology allows ED practicioners to identify patients with more than 5 ER visits in a one year period or those with complex care needs who can be directed to appropriate care. This system allows for alerts to hospitals as soon as patient visits ER.</span>
 
# <span style="background-color: #ffffff">[http://www.floridahealth.gov/statistics-and-data/e-forcse/ EFORSCE ]: Florida's PDMP. This database has been in effect since 2010 and there are [http://www.floridahealth.gov/statistics-and-data/e-forcse/news-reports/index.html annual reports ] for each year. The website also includes a list of it's [http://www.floridahealth.gov/statistics-and-data/e-forcse/funding/index.html funding sources ].</span>
 
# <span style="background-color: #ffffff">[https://pharmacypmp.az.gov/ Arizona State Board of Pharmacy Controlled Substances Prescription Monitoring Program (CSPMP) ]- Allows practitioners and pharmacists to look up, view, and print controlled substance dispensing information on their specific patients directly via user name and password.</span>
 
# <span style="color: #fa1048">[http://www.worxpdmp.com/ WORx]</span><span style="background-color: #ffffff"> Wyoming's active PDMP system.</span>
 
<br />
 
==Find Your State's PDMP==
 
Use this [http://mytopcare.org/resources/using-the-state-prescription-monitoring-program-pmp-effectively/find-your-states-pmp/ link] to find your state's Prescription Drug Monitoring Program.<br /> <br />
 
=Innovative Use of PDMP Data=
 
==Notify the Care Team that Prescribed the Opioids of the Overdose Death==
 
In Monterey County, CA, Coroners who identify that a person has died after misusing prescription opioids make use of data in the PDMP to identify and notify the care team that prescribed the opioids that their patient died. This seems to have had a big impact on prescribers and seems to have contributed to significant reductions in opioid prescription rates and increased use of non-opioid treatments for pain. (Need details and source.)<br />
 
=Tools & Resources=
 
[[TR - Expand & Enhance Prescription Drug Monitoring Programs]]<br /> <br />  The Pew Charitable Trust created a report on [http://www.pewtrusts.org/en/research-and-analysis/reports/2016/12/prescription-drug-monitoring-programs Evidence-Based Practices to Optimize Use of PDMPs]<br />
 
=Scorecard Building=
 
[[PO%20-%20Expand%20%26%20Enhance%20Prescription%20Drug%20Monitoring%20Progams|Potential Objective Details]]<br /> [[PM%20-%20Expand%20%26%20Enhance%20Prescription%20Drug%20Monitoring%20Program|Potential Measures & Data Sources]]<br /> [[PA%20-%20Expand%20and%20Enhance%20Prescription%20Drug%20Monitoring%20Program|Potential Actions & Partners]]<br />
 
=Resources to Investigate=
 
[[More Resources to Investigate on PDMP use and impact|More Resources to Investigate on PDMP Use and Impact]]<br /> <br /> <span style="background-color: #ffffff; color: #222222; font-family: arial,sans-serif; font-size: 12.8px">'''<span style="color: #4d4d4d">PAGE MANAGER</span>:''' </span><span style="background-color: #ffffff; color: #ff0000; font-family: arial,sans-serif; font-size: 12.8px">[insert name here]</span><br /> <span style="background-color: #ffffff; color: #222222; font-family: arial,sans-serif; font-size: 12.8px">'''<span style="color: #4d4d4d">SUBJECT MATTER EXPERT</span>''': </span><span style="background-color: #ffffff; color: #ff0000; font-family: arial,sans-serif; font-size: 12.8px">[fill out table below]</span><br />
 
 
{| class="wiki_table"
 
{| class="wiki_table"
| '''Reviewer'''<br />
 
| '''Date'''<br />
 
| '''Comments'''<br />
 
 
|-
 
|-
| <br />
+
| '''Reviewer'''
| <br />
+
| '''Date'''
| <br />
+
| '''Comments'''
 +
|-
 +
| &nbsp;
 +
| &nbsp;
 +
| &nbsp;
 
|}
 
|}
=Sources=
+
 
 +
= Sources =
  
 
----
 
----
  
# [http://www.sandiegocounty.gov/content/sdc/hhsa/programs/phs/PDMP-CURES.html]
+
#[http://www.sandiegocounty.gov/content/sdc/hhsa/programs/phs/PDMP-CURES.html [1]]  
# [https://www.bja.gov/Funding/CARA17.pdf]
+
#[https://www.bja.gov/Funding/CARA17.pdf [2]]  
# [https://www.bja.gov/ProgramDetails.aspx?Program_ID=72#horizontalTab1]
+
#[https://www.bja.gov/ProgramDetails.aspx?Program_ID=72#horizontalTab1 [3]]  
# [https://www.cdc.gov/drugoverdose/pdmp/providers.html]
+
#[https://www.cdc.gov/drugoverdose/pdmp/providers.html [4]]  
# [https://www.behavioral.net/article/how-monitor-prescription-drugs?page=3]
+
#[https://www.behavioral.net/article/how-monitor-prescription-drugs?page=3 [5]]  
# [https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6326a3.htm]
+
#[https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6326a3.htm [6]]  
# [http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2429105]
+
#[http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2429105 [7]]  
# [http://www.insurancefraud.org/IFNS-detail.htm?key=22343]
+
#[http://www.insurancefraud.org/IFNS-detail.htm?key=22343 [8]]  
# [http://www.insurancefraud.org/IFNS-detail.htm?key=22343]
+
#[http://www.insurancefraud.org/IFNS-detail.htm?key=22343 [9]]  
# [http://www.insurancefraud.org/IFNS-detail.htm?key=22343]
+
#[http://www.insurancefraud.org/IFNS-detail.htm?key=22343 [10]]  
# [http://www.drugwarfacts.org/chapter/diversion]
+
#[http://www.drugwarfacts.org/chapter/diversion [11]]  
# [https://www.bja.gov/ProgramDetails.aspx?Program_ID=72#horizontalTab1]
+
#[https://www.bja.gov/ProgramDetails.aspx?Program_ID=72#horizontalTab1 [12]]  
# [http://www.pdmpassist.org/pdf/PDMP_Funding_Options_TAG.pdf]
+
#[http://www.pdmpassist.org/pdf/PDMP_Funding_Options_TAG.pdf [13]]  
# [https://www.bja.gov/ProgramDetails.aspx?Program_ID=72]
+
#[https://www.bja.gov/ProgramDetails.aspx?Program_ID=72 [14]]  
# [https://www.bja.gov/Funding/COAPTTA17.pdf]
+
#[https://www.bja.gov/Funding/COAPTTA17.pdf [15]]  
# [https://www.bja.gov/Funding/CARA17.pdf]
+
#[https://www.bja.gov/Funding/CARA17.pdf [16]]  
# [https://guidemed.com/about-guidemed/]
+
#[https://guidemed.com/about-guidemed/ [17]]  
# [https://guidemed.com/about-guidemed/how-it-works/]
+
#[https://guidemed.com/about-guidemed/how-it-works/ [18]]  
# [https://www.linkedin.com/pulse/preventing-chronic-opioid-therapy-addiction-pdmps-alone-ron-frost]
+
#[https://www.linkedin.com/pulse/preventing-chronic-opioid-therapy-addiction-pdmps-alone-ron-frost [19]]  
# [https://www.bja.gov/programs/pmixarchitecture.pdf]
+
#[https://www.bja.gov/programs/pmixarchitecture.pdf [20]]  
</div>
+
</div> </div>

Revision as of 00:31, 10 January 2019

Return to Opioid Top-Level Strategy Mapor Zoom Map (Expand & Enhance PDMP) 

or Zoom Map (Reduce Access to Opioids)
or Zoom Map (Minimize Diversion of Prescription Drugs)
 

Purpose

Prescription Drug Monitoring Programs (PDMP) allows pre-registered users including licensed healthcare prescribers eligible to prescribe controlled substances, pharmacists authorized to dispense controlled substances, law enforcement, and regulatory boards to access timely patient controlled substance history information.[1]

PDMPs are designed to collect, monitor, and analyze electronically transmitted prescribing and dispensing data submitted by pharmacies and dispensing practitioners. This information is used to assist prescribers, dispensers, and other health care professionals in making clinical decisions for their patients. PDMPs also have been shown to reduce adverse drug interactions, and help health care professionals identify patients who may be in need of substance use treatment. Law enforcement and regulatory/licensing board officials utilize PDMP information, under appropriate circumstances, to further their investigations of suspected violations of controlled substance laws and compliance with regulatory/licensing board practice standards. Many states have also begun to use PDMPs as a public health surveillance tool. PDMPs continue to be among the most promising state-level interventions to improve opioid prescribing, inform clinical practice, and protect patients at risk.[2]

The main objectives of these programs are to:

  • Improve patient safety.
  • Build a data collection and analysis system at a state level.
  • Enhance existing programs' ability to analyze and use collected data.
  • Facilitate the exchange of collected prescription data among states.
  • Assess the efficiency and effectiveness of the programs funded under this initiative.[3]


PDMPs can alert Healthcare Providers to provide potentially lifesaving information and interventions.

  • They DO for those using prescription opioids
    • Help collaborate with the patient to taper to a safer dosage
    • Consider offering naloxone
    • Communicate with other providers managing the patient
    • Weigh patient goals, needs, risks
  • They DO for those who they consider to have opioid use disorder, discuss safety concerns and treatment options[4]
  • They DO NOT dismiss patients from care


With this in mind, states are trying to find ways to increase use of PDMPs by prescribers so they avoid having a mandate. In some states, you are automatically registered when practitioners apply for a license. There are also efforts to integrate PDMP data into electronic medical record systems so the information is available at the point of care.[5]
 

Impact

Positive

  • Between the years of 2010-2012 Florida implemented a PDMP and other "pill mill" policies that had an positive impact on the opioid epidemic. According to the CDC, Florida recorded a 26.1% decrease in opioid analgesic overdose deaths, after these policies were implemented.[6] The Florida Department of Health said that from 2010 to 2013, oxycodone overdose deaths fell from 1,516 to 534—a 65% decrease.[7]
  • New York Experienced a 75% decrease in prescriptions issued through "doctor shopping" as a result of a 2012 requirement that prescribers check the PDMP before writing a prescription.[8]
  • 74% of California physicians reportedly changed their prescribing practice as a result of patient activity reports created using the state's PDMP[9]
  • After establishing a PDMP, Tennessee saw a reduction in the morphine milligram equivalents dispensed, a reduction in the number of doctor and pharmacy shoppers going to multiple outlets to obtain drugs, an increase in queries to the State's Controlled Substance Monitoring Database Program by prescribers and extenders, and a change in practices, with some 41.4% less likely to prescribe certain controlled substances.[10]

 

Negative

The existence of a Prescription Drug Monitoring Program within a state, however, appears to increase drug diversion activities in contiguous non-PDMP states. When states begin to monitor drugs, drug diversion activities tend to spill across boundaries to non-PDMP states. One example is provided by Kentucky, which shares a boundary with seven states, only two of which have PDMPs -- Indiana and Illinois. As drug diverters became aware of Kentucky PDMP's ability to trace their drug histories, they tended to move their diversion activities to nearby nonmonitored states. OxyContin diversion problems have worsened in Tennessee, West Virginia, and Virginia -- all contiguous non-PDMP states -- because of the presence of Kentucky's PDMP, according to a joint federal, state, and local drug diversion report.[11]
 
 

Legislation

The Prescription Drug Monitoring Program was created by the FY 2002 U.S. Department of Justice Appropriations Act (Public Law 107-77). [12]
 
 

Funding Opportunities

Current Funding Methods

  • Federal grants
  • Private/Non-federal grants
  • General revenue funds
  • Controlled substance registration fees
  • Professional licensing fees
  • Regulatory board funds

Potential Funding Methods

  • Legal settlements
  • PDMP licensing fees
  • Health insurance licensing fees
  • Private donations
  • Medicaid fraud settlements
  • Assessed fines
  • Asset Forfeiture
  • Drug manufacturers' assessment
  • Prescription fees
  • Private third party payers or health insurers
  • PDMP authorized users [13]
  • see the PDMP TTAC Funding Options for Prescription Drug Monitoring Programs in Tools and Resources for full descriptions.

    The Comprehensive Opioid Abuse Program Training and Technical Assistance (TTA) Program is a grant from the U.S. Bureau of Justice given to state, local, and tribal governments to provide resources to intervene with persons with substance use disorders.[14] The goals of the Comprehensive Opioid Abuse TTA Program are twofold. First, the program aims to support site-based and state initiatives designed to reduce opioid misuse and the number of overdose fatalities. Second, the program supports PDMPs and their stakeholders in expanding the implementation, enhancement, and proactive use of prescription drug monitoring programs to support clinical decision-making and prevent the misuse and diversion of controlled substances. Proposals due April 25, 2017.[15]

    The Comprehensive Opioid Abuse Site-based Program - Harold Rogers Prescription Drug Monitoring Program Implementation and Enhancement Projects
    Funding opportunity which provides state, local, and tribal governments resources to intervene with persons with substance use disorders.The Harold Rogers Prescription Drug Monitoring Program (PDMP) is being incorporated into the FY 2017 Comprehensive Opioid Abuse Site-based Program. The purpose of this program is to improve collaboration and strategic decision-making of regulatory and law enforcement agencies and public health officials to address prescription drug and opioid misuse, save lives, and reduce crime. This is made possible through the collection and analysis of controlled substance prescription data and other scheduled chemical products through a centralized database administered by an authorized state agency. This program will be applied by April 25, 2017.[16]

Opportunities to Enhance PDMPs

TTAC

Training Technical Assistance Center : Brandeis University, in partnership with the Bureau of Justice Assistance, has developed the PDMP TTAC to provide services, support, resources and strategies to improve the effectiveness of state PDMPs. Call 781-609-7741 for more information.

Third Party Patient Monitoring

GuideMed Monitoring is a management program for prescription narcotics monitoring. It helps provider networks prevent prescription drug misuse and it helps to protect the network and its practitioners from liabilities associated with prescription narcotics.[17] Patient service stations are established on-site or freestanding in locations determined by the physician, where GuideMed nurses will staff and manage the monitoring activities chosen by the physician (Risk Assessments, PDMP Checks, CSA Reviews, Pill Counts, Toxicology Testing). After the nurse gathers all the necessary information, a report is prepared and sent to the patient's physician via a PDF file attached to that patient's record. GuideMed also provides any data needed for a compliance officer.[18]

Provider Challenges to Effective Use of PDMPs

  • Insufficient Resources: Providers lack the time within their practice to perform all activities (not staffed sufficiently, not reimbursed, not value-added). Virtually every knowledge and use survey for PDMPs, for example, shows only half of physicians use the PDMP and the reasons cited for not using it are "it's too time consuming" and "its too difficult to use." ("I need to see a patient every 12 minutes to make ends meet, I do not have the time or capacity to do all of this work.")
  • Patient Provider Relationship: The design of many programs tends to compromise the trust between patients and physicians because the providers are required to police their patients, and this is not something physicians see as part of their role as care providers. ("I did not go to medical school for this. I need a trusting relationship with the patient, which is not possible when I ask to count their pills.")
  • Data Management: There is no automation support for any of this activity today, no field within the EMR to enter the risk-adjusted monitoring protocols or schedule patient activities according to risk levels, there is no place to store the results of a pill count or PDMP check or alert the physician when a treatment agreement needs to be updated.
  • Consistency: Whether it is patients within a practice, practices within a network, or health systems within the state -- getting everyone to establish and adhere to protocols consistently is a challenge, yet inconsistent application of protocols is one of the greatest liabilities for any provider.[19]


Prescription Drug Monitoring Information Exchange (PMIX) Architecture enables nationwide information sharing by the use of free, open, and consensus-based solutions; a common formatting of shared data; security and privacy protocols to protect sensitive information; and preserving the state choice of interstate sharing solutions.[20]

Use PDMPs to Improve Patient Safety

National Alliance for Model State Drug Laws

View model PDMP laws  and documents from states with prescription drug monitoring programs
 
  • Annual summaries or highlights
  • Administration of PDMPs
  • Data Reporting and Retention
  • Types of Authorized Recipients
  • Access and Registration
  • PDMPs and Privacy
  • Miscellaneaous Documents

State PDMPs

  1. CURES : California's state PDMP. Learn more at CURES FAQs
  2. EDIE : Oregon and Washington use the Emergency Department Information Exchange (EDIE) system. This technology allows ED practicioners to identify patients with more than 5 ER visits in a one year period or those with complex care needs who can be directed to appropriate care. This system allows for alerts to hospitals as soon as patient visits ER.
  3. EFORSCE : Florida's PDMP. This database has been in effect since 2010 and there are annual reports for each year. The website also includes a list of it's funding sources .
  4. Arizona State Board of Pharmacy Controlled Substances Prescription Monitoring Program (CSPMP) - Allows practitioners and pharmacists to look up, view, and print controlled substance dispensing information on their specific patients directly via user name and password.
  5. WORxWyoming's active PDMP system.

 

Find Your State's PDMP

Use this link to find your state's Prescription Drug Monitoring Program.
 
 

Innovative Use of PDMP Data

Notify the Care Team that Prescribed the Opioids of the Overdose Death

In Monterey County, CA, Coroners who identify that a person has died after misusing prescription opioids make use of data in the PDMP to identify and notify the care team that prescribed the opioids that their patient died. This seems to have had a big impact on prescribers and seems to have contributed to significant reductions in opioid prescription rates and increased use of non-opioid treatments for pain. (Need details and source.)
 

Tools & Resources

TR - Expand & Enhance Prescription Drug Monitoring Programs

The Pew Charitable Trust created a report on Evidence-Based Practices to Optimize Use of PDMPs

Scorecard Building

Potential Objective Details
Potential Measures & Data Sources
Potential Actions & Partners

Resources to Investigate

More Resources to Investigate on PDMP Use and Impact

PAGE MANAGER: [insert name here]
SUBJECT MATTER EXPERT: [fill out table below]

Reviewer Date Comments
     

Sources


  1. [1]
  2. [2]
  3. [3]
  4. [4]
  5. [5]
  6. [6]
  7. [7]
  8. [8]
  9. [9]
  10. [10]
  11. [11]
  12. [12]
  13. [13]
  14. [14]
  15. [15]
  16. [16]
  17. [17]
  18. [18]
  19. [19]
  20. [20]