Background
The Maryland Prescription Drug Monitoring Program (PDMP), collects information on all Schedule II – V controlled dangerous substance (CDS) prescriptions dispensed in Maryland, and makes these data available to authorized end users. In addition to disclosing data when solicited by authorized users, the Maryland PDMP may also proactively notify certain individuals or entities when outlying patient or prescriber behavior is identified. Unsolicited Reporting is the activity of analyzing PDMP data for an indicator of concern and then proactively reporting PDMP data to a specific individual or entity based on the analysis finding.
Unsolicited reporting is considered a national best practice and has been adopted by a majority of states. Under HB025 (Chapter 531, Prescription Drug Monitoring Program – Revisions, 2019), the Office of the PDMP is required to review prescription monitoring data for indications of possible misuse or abuse of a prescription drug by a patient; possible violations of law and possible breaches of professional standards by a prescriber or a dispenser and provide education to providers who are identified.
The letters, also referred to as Unsolicited Reporting Notifications or URNs, are provided for educational and practice improvement purposes with the goal of supporting clinical decision-making and reducing the risk of adverse outcomes for patients receiving CDS prescriptions. The letters are not public record. Providers should use their clinical judgement in interpreting the URNs and within the context of the provider's patient panel, patients' history, diagnosis, care plan, involvement with hospice, or complex pain management needs. Each URN sent by the Program includes educational resources.
Since 2016, the Office of the PDMP has been sending URNs through the mail based on the address prescribers provide to the DEA; in 2022 the Program began shifting to sending URNs electronically.
Process
The Office of the PDMP works closely with the PDMP Technical Advisory Committee (TAC) in determining which metrics to use in assessing the PDMP data for possible misuse or abuse of a prescription drug, possible violations of law, and possible breaches of professional standards by a provider. The TAC consists of MDH-Secretary appointed clinicians who serve as subject matter experts on CDS prescribing and dispensing (Health-General Article section 21-2a-07). Each month, the Office of the PDMP analyzes the PDMP data for possible concerning behaviors on behalf of a patient or provider based on clinical guidance provided by the TAC.
