8 ms·

This is an odd proposal. Most importantly: we need to start treating drug addiction, and long term pain, as the public health emergencies they are and we need

by DanBC 6y ago

This is an odd proposal. Most importantly: we need to start treating drug addiction, and long term pain, as the public health emergencies they are and we need to stop criminalising drug addicts. > Diversion investigations involve, but are not limited to, practitioners and mid-level practitioners who write prescriptions for no legitimate medical need and/or outside the scope of legitimate medical practice, or sell prescriptions to drug dealers or abusers; pharmacists who falsify records and subsequently sell or abuse the drugs; pharmacists who fill prescriptions that they knew or should have known were illegitimate; employees who steal from inventory and falsify records to cover illicit sales; prescription forgers; and individuals who commit armed robbery of pharmacies and drug distributors The US does massively over-prescribe opioids. There have been doctors who were careless in who they prescribed to. There have been "pill mills" https://www.theguardian.com/us-news/2019/oct/02/opioids-west-virginia-pill-mills-pharmacies https://www.theguardian.com/us-news/2019/oct/02/opioids-west... But they don't need patient ID to track that down. They can use supplier data. I'm also struggling to read the document. It's written in a specific, jargon heavy, way. Use of the word "subpoena" every time they mention patient data is a little bit reassuring, but it's still not great. > CLIN 2001 Unlimited access to patient de-identified data, to be identified via subpoena, for class 2 to 5 prescription data which includes pharmacy, medical, and dental data. Fixed price per license per month I'm still ploughing through the 60 pages to try to get my head around it.

DanBC 6y ago
So, task one talks about encrypted patient identifiers. This makes it sound like they're not going after patients, but are targetting pharmaceutical companies and doctors. Task 1: Provide and maintain data on a minimum of 85 percent of all prescriptions for Schedule/Class II through V prescription drugs (additional non-controlled items may be requested for possible scheduling actions) written and/or filled in the United States and trust territories: a) Prescription data shall include, but is not limited to: • The number of prescriptions filled, • The number of new prescriptions filled, • The number of refills filled, by date filled, • The name of the controlled substance • The days’ supply for the patient (e.g. 5 days, 15 days, et.), • The prescribers name and DEA registration number, and specialty • An encrypted patient identifier to whom the prescription was written • Date prescription was dispensed • Payment Type: cash, government payer, commercial payer • Dosing information: quantity and days’ sup --- Here's the patient information they want: > Patients • Number of instances of more than one Schedule II prescription for the same drug, and written within three days of each other by different prescribers • Number of instances of more than one Schedule II prescriptions for the same drug and written within three days of each other by the same prescriber • Number of instances of more than two patients, with the same address, receive the same drug in the same quantity from the same doctor on the same day. • Number of early refills Opiate and Benzo combine • Number of early Schedule II • Distance between patient and pharmacy • Average distance between patient and pharmacy for a combination of Opiate, Benzo and a muscle relaxer. • Distance between patient and pharmacy for Schedule II • Distance between patient and prescriber • Distance between patient and prescriber for Schedule II • Number of Opiate and Buprenorphine combinations • Number of Paid “cash” Schedule II • Number of Oxycodone 30 MG and 15 MG within five days overlap • Number of times Opioid Cough Syrup exceeds 90 day supply • Number of Oxycodone 30 MG and Hydromorphone 8 MG within five days overlap • Average MME Per Day • Average Total MME per pharmacy visit • Number of Opiate and Benzo combine within 3 days • Number of Opiate and Benzo prescriptions for the same person on the same filled day at different pharmacies. • Number of Opiate and Benzo prescriptions filled for the same person on the same day from different prescribers • Number of Opiate and Benzo prescriptions written on the same day to the same person by different prescribers • Number of Opiate and Benzo filled on the same person on the same day • Number of Opiate and Benzo filled for the same person on the same day at the same pharmacy They also say this: > f) Fully HIPAA-compliant. > Current pharmacy and prescription data updated on a daily basis. > Task 2: Streamline process for requesting the unmasking of pharmacy information. (PII shall be withheld or redacted unless specifically requested by subpoena.)
- La1n 6y ago
  >Here's the patient information they want: You are missing the page before: >Non-specific patient demographics (gender; age group; city, state, and zip code of residence) This doesn't seem HIPAA compliant according to the safe habor rules: https://www.hhs.gov/hipaa/for-professionals/privacy/special-topics/de-identification/index.html#safeharborguidance https://www.hhs.gov/hipaa/for-professionals/privacy/special-... It would also be almost impossible to use expert determination, for this is often done using statistical methods that are impossible to apply on changing datasets (such as k-anonymity). edit: They also ask for an "encrypted patient identifier".
teekert 6y ago
Someone I know once got Opioids to take home after a hospital visit, she said she didn't want them, they urged her to take them anyway. Turns out the hospital was sponsored by the producer of the pills. This is not just over-prescribing, this is intentionally creating addicts and should be criminalized asap.
- m1gu3l 6y ago
  meanwhile the dentist doesn’t want to give me anything stronger than tylenol with codine because idiots like this hospital ruined it for everyone.
  - justanother 6y ago
    Oh, fancy pants up there gets codeine! After my extractions, I was sent home with straight-up Tylenol. But it isn't just the USA. In France, my wife had to nearly beg for strong pain relief for her back, but at least the doctor only charged 35 euros for a visit.
    - teekert 6y ago
      Pain has its benefits, it's not just there to annoy you, it is there to tell you not to try and chew with that gaping hole in your jaw. So I understand that a Dentist may sometimes say: Just suck it up, who are you to judge that life should be without pain entirely? Still, I do believe you should be entitled to make your own choices but the physician should educate you before you do so, imho. I am from the Netherlands where natural birth without painkillers is also still the norm. You can always opt for them and cesarean but one should know that numbing everything away and taking the kid through a newly cut hole also has its downsides (studies show). Spoken like a true man ;) Seriously, I'm not judging, just sayin'.
    - m463 6y ago
      Maybe more folks should be asking why the teeth need to come out. (It could be legit, I don't know your case!) But every dentist I've had - every - has asked about taking out my wisdom teeth. And not one of them could give me a good justification. I still have them. A legitimate reason MIGHT be you can't be a navy seal if you have your wisdom teeth because apparently something with deep diving affects them. :)
coronadisaster 6y ago
> The US does massively over-prescribe opioids. Jail the doctors. They are getting bribes from drug companies.
- pnw_hazor 6y ago
  Recently Schedule II prescriptions are reported to state or multi-state registries that local government officials including police can view at will. My provider makes me sign an expansive privacy waiver to get my prescription. I gave up the drug for awhile because of it, I had to come crawling back and sign it. The AMA embraces this total abdication of their responsibility to protect patient privacy. A federal registry is the natural next step. As an attorney I cannot imagine selling out my clients the way MD's do.
gumby 6y ago
> Most importantly: we need to start treating drug addiction, and long term pain, as the public health emergencies they are and we need to stop criminalising drug addicts. You might be (not at all) surprised to learn that the largest opposition to this shift is the DEA itself (It's the DEA's fault, for example, that it's so difficult for addicts to get Suboxone even when prescribed). In terms of lobbying dollars, #1 is the police and prison guards union.

by DanBC 6y ago

DanBC 6y ago

So, task one talks about encrypted patient identifiers. This makes it sound like they're not going after patients, but are targetting pharmaceutical companies and doctors. Task 1: Provide and maintain data on a minimum of 85 percent of all prescriptions for Schedule/Class II through V prescription drugs (additional non-controlled items may be requested for possible scheduling actions) written and/or filled in the United States and trust territories: a) Prescription data shall include, but is not limited to: • The number of prescriptions filled, • The number of new prescriptions filled, • The number of refills filled, by date filled, • The name of the controlled substance • The days’ supply for the patient (e.g. 5 days, 15 days, et.), • The prescribers name and DEA registration number, and specialty • An encrypted patient identifier to whom the prescription was written • Date prescription was dispensed • Payment Type: cash, government payer, commercial payer • Dosing information: quantity and days’ sup --- Here's the patient information they want: > Patients • Number of instances of more than one Schedule II prescription for the same drug, and written within three days of each other by different prescribers • Number of instances of more than one Schedule II prescriptions for the same drug and written within three days of each other by the same prescriber • Number of instances of more than two patients, with the same address, receive the same drug in the same quantity from the same doctor on the same day. • Number of early refills Opiate and Benzo combine • Number of early Schedule II • Distance between patient and pharmacy • Average distance between patient and pharmacy for a combination of Opiate, Benzo and a muscle relaxer. • Distance between patient and pharmacy for Schedule II • Distance between patient and prescriber • Distance between patient and prescriber for Schedule II • Number of Opiate and Buprenorphine combinations • Number of Paid “cash” Schedule II • Number of Oxycodone 30 MG and 15 MG within five days overlap • Number of times Opioid Cough Syrup exceeds 90 day supply • Number of Oxycodone 30 MG and Hydromorphone 8 MG within five days overlap • Average MME Per Day • Average Total MME per pharmacy visit • Number of Opiate and Benzo combine within 3 days • Number of Opiate and Benzo prescriptions for the same person on the same filled day at different pharmacies. • Number of Opiate and Benzo prescriptions filled for the same person on the same day from different prescribers • Number of Opiate and Benzo prescriptions written on the same day to the same person by different prescribers • Number of Opiate and Benzo filled on the same person on the same day • Number of Opiate and Benzo filled for the same person on the same day at the same pharmacy They also say this: > f) Fully HIPAA-compliant. > Current pharmacy and prescription data updated on a daily basis. > Task 2: Streamline process for requesting the unmasking of pharmacy information. (PII shall be withheld or redacted unless specifically requested by subpoena.)

La1n 6y ago
>Here's the patient information they want: You are missing the page before: >Non-specific patient demographics (gender; age group; city, state, and zip code of residence) This doesn't seem HIPAA compliant according to the safe habor rules: https://www.hhs.gov/hipaa/for-professionals/privacy/special-topics/de-identification/index.html#safeharborguidance https://www.hhs.gov/hipaa/for-professionals/privacy/special-... It would also be almost impossible to use expert determination, for this is often done using statistical methods that are impossible to apply on changing datasets (such as k-anonymity). edit: They also ask for an "encrypted patient identifier".

teekert 6y ago

Someone I know once got Opioids to take home after a hospital visit, she said she didn't want them, they urged her to take them anyway. Turns out the hospital was sponsored by the producer of the pills. This is not just over-prescribing, this is intentionally creating addicts and should be criminalized asap.

m1gu3l 6y ago
meanwhile the dentist doesn’t want to give me anything stronger than tylenol with codine because idiots like this hospital ruined it for everyone.
- justanother 6y ago
  Oh, fancy pants up there gets codeine! After my extractions, I was sent home with straight-up Tylenol. But it isn't just the USA. In France, my wife had to nearly beg for strong pain relief for her back, but at least the doctor only charged 35 euros for a visit.
  - teekert 6y ago
    Pain has its benefits, it's not just there to annoy you, it is there to tell you not to try and chew with that gaping hole in your jaw. So I understand that a Dentist may sometimes say: Just suck it up, who are you to judge that life should be without pain entirely? Still, I do believe you should be entitled to make your own choices but the physician should educate you before you do so, imho. I am from the Netherlands where natural birth without painkillers is also still the norm. You can always opt for them and cesarean but one should know that numbing everything away and taking the kid through a newly cut hole also has its downsides (studies show). Spoken like a true man ;) Seriously, I'm not judging, just sayin'.
  - m463 6y ago
    Maybe more folks should be asking why the teeth need to come out. (It could be legit, I don't know your case!) But every dentist I've had - every - has asked about taking out my wisdom teeth. And not one of them could give me a good justification. I still have them. A legitimate reason MIGHT be you can't be a navy seal if you have your wisdom teeth because apparently something with deep diving affects them. :)

coronadisaster 6y ago

> The US does massively over-prescribe opioids. Jail the doctors. They are getting bribes from drug companies.

pnw_hazor 6y ago
Recently Schedule II prescriptions are reported to state or multi-state registries that local government officials including police can view at will. My provider makes me sign an expansive privacy waiver to get my prescription. I gave up the drug for awhile because of it, I had to come crawling back and sign it. The AMA embraces this total abdication of their responsibility to protect patient privacy. A federal registry is the natural next step. As an attorney I cannot imagine selling out my clients the way MD's do.

gumby 6y ago

> Most importantly: we need to start treating drug addiction, and long term pain, as the public health emergencies they are and we need to stop criminalising drug addicts. You might be (not at all) surprised to learn that the largest opposition to this shift is the DEA itself (It's the DEA's fault, for example, that it's so difficult for addicts to get Suboxone even when prescribed). In terms of lobbying dollars, #1 is the police and prison guards union.