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So, task one talks about encrypted patient identifiers. This makes it sound like they're not going after patients, but are targetting pharmaceutical companies a
by 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
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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".