Prescription Monitoring Program

A successful prescription monitoring program must fulfill three essential requirements. The data it contains – about the drug, patient, prescriber and pharmacist – should be complete, accurate and available to prescribers in a timely manner. The law defines “timely” as within one day of distributing a prescription. By accessing their state’s PMP system, medical professionals can review medications their patients received in the past before prescribing or dispensing new or additional medicines.

Washington’s PMP began operating in 2011 and is administered by the Department of Health (DOH). State law requires pharmacies to submit to the PMP system all Schedule II-V controlled-substance prescriptions that they give to a patient. In addition, most medical professionals must check the PMP before prescribing controlled substances. The Washington State Hospital Association and the Washington State Medical Association jointly oversee the Better Prescribing, Better Treatment Collaborative. The Collaborative uses PMP system data from DOH to create opioid prescribing reports. The Collaborative distributes these reports to educate medical professionals about their prescribing practices and how they compare to their peers.

Prescription records should be complete, and the data uploaded within the time set out in law. Up-to-date entries in the PMP database help reassure prescribers they have a full view of the patient’s prescriptions for other controlled substances. Monitoring the database for complete and timely submissions forms an important part of that reassurance.

The audit found that roughly one-quarter of prescriptions were uploaded to the system late. In addition, it found DOH does not monitor PMP data to see if pharmacies submit prescription records within one day of distributing to a patient. Instead, starting in January 2022, DOH initiated a process to check for pharmacies that have not submitted any prescription records to the PMP on a given day. The agency performs this review a couple of times a month. DOH then contacts some of the pharmacies that have not submitted data for the highest number of consecutive days, alerting them to the gap in reporting dates and helping them resolve the issue.

In addition, DOH lacks a process to determine whether pharmacies have submitted all required prescriptions to the PMP system. At the moment, neither DOH nor the Pharmacy Commission has established requirements for pharmacies to perform an independent review and reconciliation of their own systems to the PMP database. For this reason, the state lacks an assurance pharmacies submit all the records they should.

The PMP system automatically blocks prescription records with data errors from uploading into the system. Until recently, DOH did not contact pharmacies that failed to correct prescription records with such errors. 

We analyzed PMP data on records that did not upload to the PMP database due to uncorrected errors. We found about 12,000 uncorrected records, out of an estimated 12 million uploaded to the PMP system in the past year. This is about 0.1 percent of records submitted in a year — a very small percentage. But most of the uncorrected errors came from a very small number of pharmacies. If DOH worked with the handful of pharmacies with the most errors, doing so would lead to the correction of thousands of errors. In turn, that would mean that many more correct, complete records would be available to prescribers within the PMP system.

Opioid prescribing reports contain information about the prescribing activity of the health care professionals who prescribe them. These reports help some, but not all, of Washington’s medical professionals understand their own prescribing behavior. They can readily see how their prescribing activity compares to their peers. Since 2019, the Better Prescribing, Better Treatment Collaborative has used PMP data to send opioid prescribing reports to medical professionals. Further enhancements to the reports could increase their usefulness to prescribers. The Collaborative would need to work with other professional associations to expand the reach of these reports. It is likely the Collaborative would need extra resources to reach more health care professionals in other fields.

As the lead state health agency, DOH is well positioned to help. It can bring together stakeholders to help the Collaborative improve the reports and expand their reach.

State law restricts access to PMP data to protect patients, prescribers and pharmacies. The restrictions curtail independent oversight that might identify opportunities for improvement. Auditors in other states used PMP data to identify prescribing and dispensing patterns of concern. We could not replicate the work in their audits due to the data restrictions in Washington. Additionally, our ability to examine certain system processes was limited. For example, we could not view data that identified pharmacies, so we could not see which might have been persistently late uploading data. These restrictions in state law inhibited our ability to complete this planned audit work. Furthermore, neither DOH nor the regulatory licensing boards and commissions analyze PMP data in search of those concerning patterns.

We recommended DOH update its administrative rules in the Washington Administrative Code (WAC). Doing so can help ensure pharmacies submit all required prescriptions records in a timely manner. The agency could also improve its internal processes to check that pharmacies have submitted prescription records promptly.

To expand the reach of opioid prescribing reports to more medical professionals, we recommended DOH take part in a workgroup with the Better Prescribing, Better Treatment Collaborative. We also recommended the Pharmacy Commission make some additions to pharmacy inspection processes that will help ensure completeness of PMP data. Finally, we made a recommendation to the Legislature to amend state law so that independent auditors can have the authority to access identifiable PMP data.