1. Collecting data outlined in the state PDMP law, Pharm 18.
2. Submitting any PDMP data collected since the law took effect on Jan. 1, 2013.
I am torn on how to feel or what to think. On one hand, they are claiming this burden on veterinarians would have cost $7 million a year to the industry, ultimately passed on to the consumer of veterinary services. So kudos to the Wisconsin Veterinary Medical Association for protecting their members from the costly burden of recording and reporting and for protecting the consumer against increased costs of veterinary care.
On the other hand, the Prescription Drug Monitoring Program (PDMP) was introduced by the Pharmacy Board division of the Wisconsin Department of Safety and Professional Services, formerly the Department of Regulation and Licensing, to protect the public. “The Wisconsin Prescription Drug Monitoring Program (PDMP) is a tool to improve patient care and safety and to reduce the abuse and diversion of prescription drugs.” The duty of this department, which licenses all professionals in Wisconsin except attorneys, is to protect the public–the consumer and their property/animals–not the veterinarian.
The nuts and bolts of how to report data to this monitoring program have just now been fleshed out, despite the act taking effect January 1, 2013. The crux of the program was that every controlled substance drug and a few on the fringes of controlled drugs were to be recorded and reported, along with the birthdate of the consumer, to the PDMP program. The reports were to be done weekly for prescribers to humans and quarterly for prescribers to animals. In doing so, the Pharmacy Board was using this data to track and minimize prescriptions that were being overfilled by pharmacies, doctors, other human health care professionals and veterinarians. Most of the controlled substances prescribed by veterinarians are human drugs as an animal equivalent does not exist.
Veterinarians were included as prescribers as there is the suspicion of some drug diversion from Fido, Bessie, Fluffy, and Trigger. Of course, no prescriber, whether to the human or veterinary patient, wants to believe that the drugs they prescribe in good faith are not being used as intended. But reality is that this is a big problem, one without supporting data because of the cleverness of the diverter. And sometimes a veterinarian suspects that this is happening, but it is a hard problem with which to confront a client or patient. Having the state monitor and manage potential drug mis-prescribing or drug diversion would be a much more effective system than asking the veterinary staff to police their clients for signs of inappropriate drug use.
At our practice, we had geared up for this to happen as we had known about it since mid 2012. Most of the drugs involved were already recorded in our system for quantity dispensed and to whom. So that only required reporting them, and reporting could be done on paper or electronically. The two missing pieces were 1. that a few new drugs were included, and 2. biggest of all for the veterinary industry, was that we needed to record and report the date of birth of the person the drugs were going to. But then came the dilemmas–whose birthdate were we to report and where were we going to record it?
The date of birth was that of the “owner”, not the person the drugs were handed to or the prescription was provided to. But who is the owner? The husband, wife, handler, partner, parent, child, caretaker, neighbor, boarding kennel and so on as all of these are people we regularly have legal permission to work with? If a son called in for a refill and picked up medication “for the dog”, but mom and dad don’t know about it and don’t know how many veterinarians the son has taken the dog to for “pain”, how is this helpful?
Additionally, we have no precedent or computer fields to enter this data into. Clients were caught off guard and offended by us asking for personal information about them. They happily tell us about their personal habits as they relate to their pets–that they sleep with the cat, go to the bathroom with the dog, dress up the dog, lick the same ice cream cone as the cat. But ask for their birthdate? That crossed a line. It was clear from the Pharmacy Board, however, that we needed to provide a human’s birthdate, not that of the pet. Approximately one quarter of our animal patients have a date of birth of the first day of the month of their estimated date of birth, and that is too easy to change–no social security numbers for our pets! And is a date of birth a unique enough identifier for the state to hang their entire Prescription Drug Monitoring Program on?
Despite 42 other states having prescription drug monitoring programs, Wisconsin has now had a large hole gnawed right through the very tool meant to protect the consumer. Is that worth the price we just saved the veterinary industry?
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