Report of the NABP PMP InterConnect Steering Committee Conference Call April 17, 2013

Transcription

1 Report of the NABP PMP InterConnect Steering Committee Conference Call April 17, 2013 Member States Present: Virginia, chair; Arizona; Arkansas; Colorado; Connecticut; Delaware; Idaho; Illinois; Indiana; Kansas; Kentucky; Louisiana; Mississippi; New Mexico; North Dakota; Ohio; South Carolina; South Dakota; Tennessee; Utah; and West Virginia. Member States Absent: Michigan, Minnesota, and Nevada. Ex Officio Members Present: Montana, North Carolina, Rhode Island, and Wyoming. Others Present: Mark Conradi, Executive Committee liaison; Clay Rogers, Appriss, Inc; and Carmen Catizone, Robert Cowan, Josh Bolin, Danna Droz, Sally Stein, Lawana Lyons, and Lisa Huxhold, NABP staff. Introduction: The NABP PMP Interconnect Steering Committee met on April 17, 2013, via conference call. Steering Committee Chairperson Ralph Orr welcomed attendees and called the roll. Announcements: NABP staff provided a brief update on housekeeping items beginning with the introduction of Danna Droz, NABP s new prescription monitoring program (PMP) liaison, as of April 8. Droz is to be the primary NABP contact relating to PMPs. Staff explained how NABP and NABP PMP InterConnect have operated and what the hope is now that the Association has a dedicated individual to assist with PMP-related tasks. Initial efforts began with the overall politics of interstate data sharing and getting the states on board to share as much PMP data as possible. Droz s role will be to assist with the day-to-day interactions of the states to increase data sharing. Droz will soon be reaching out to those states that are already connected to NABP InterConnect in addition to those states who are working toward connection. NABP realizes the importance of having dedicated staff to interact more frequently with the state PMPs. Next, NABP staff shared that they are exploring the option of holding a summer 2013 inperson Steering Committee meeting at NABP Headquarters. Staff plans to work with the internal NABP meetings staff on details of the meeting after the upcoming NABP 109 th Annual Meeting, NABP s largest meeting. Logistics will come out well in advance of the

2 meeting date, but members should tentatively plan for the meeting to take place the last week of July or the first week of August Staff then reviewed the NABP InterConnect numbers. Currently, there are 24 states with executed memorandums of understanding (MOUs). Arkansas, Colorado, Delaware, Minnesota, Nevada, and Tennessee are the most recent states to have executed MOUs. Staff is happy to work with other states and their software vendors to assist with connection. Fourteen states are actually connected and using NABP InterConnect. The next focus for the program will be to broaden the use of NABP InterConnect among states and with other health care entities. Prior to proceeding with the formal agenda items, Orr asked if other states had joined the call. North Dakota, Ohio, and South Dakota joined. ONC Standards and Interoperability Group: NABP staff acknowledged that as PMP administrators, many of the Steering Committee members have most likely already heard of the development of the Office of the National Coordinator for Health Information Technology (ONC) and the Standards and Interoperability Framework. The framework development is administered by MITRE the same organization that administered the various pilots and is an outgrowth of these. MITRE was charged with looking at how the data goes in and out of the PMPs. More specifically, they looked at ways to see how the PMP data flows out of the PMP and into health care. NABP is working with Appriss to make sure that the PMPs will not be impacted no matter what happens with the ONC framework. One of ONC s goals through this framework is to create seamless communication from the PMP to the electronic health record or health information exchange. Currently, the PMPs and NABP InterConnect all communicate through a standard language, the National Information Exchange Model, or NIEM; however, no one in health care speaks NIEM. Relating to this need for seamless communication and a common language, as directed by the Steering Committee during the September 2012 meeting, NABP and Appriss worked to develop a translation proxy service. This would allow the PMPs to keep their language but also allow a better flow of data to National Council for Prescription Drug Programs (NCPDP), Health Level 7 International (HL7), American Society for Automation in Pharmacy (ASAP), etc. The creation of this proxy service was to fill two purposes: (1) facilitate rapid integration; and (2) assist with Prescription Monitoring Information Exchange (PMIX) architecture compliance. Staff recognized that the primary barriers for health care entities to connect to the PMPs are cost and ease of integration. Many PMPs have incentivized these connections through grant funding. Providing data in a health care entity s native language will make integration much easier and therefore will encourage rapid adoption. Staff next discussed the possible evolution of the ONC framework. Staff shared that they are currently exploring the mapping of NIEM to the other languages (NCPDP, HL7, and

3 ASAP), and will coordinate with ONC as appropriate. ONC is paying close attention to what NABP is currently developing with the translation service with the possibility of creating a standard. This will allow the PMPs to remain involved. Creating a standard language may not change the way PMPs communicate, but it may have an impact on some of the software vendors. This will not, however, affect NABP InterConnect, as the Association is dedicated to working with the states to make the translation seamless. In the meantime, as this framework develops, NABP will continue to closely monitor the federal grant requirements to ensure that the states remain compliant and will loop in the PMPs should the Association see or hear anything that would indicate otherwise. PMIX Architecture: Following the ONC discussion, staff provided an update on the PMIX architecture. In September, the Steering Committee voted unanimously to develop the translation proxy service. This service not only helps with the security of the message, but also helps to reconcile NABP InterConnect and PMIX data. Soon after the September Steering Committee meeting, NABP staff met with the Bureau of Justice Assistance (BJA) in Washington, DC, to discuss the translation proxy service and the Steering Committee s directive. BJA approved the service, requesting a detailed technical specification. In the months following, NABP worked with Appriss to build the concept, whereby the proxy takes the request from the NABP InterConnect participating state, decrypts the message, and re-encrypts the message with RxCheck security methodology using PMIX architecture. In this service, no data will be stored at any point. The requested technical specifications were provided to BJA. Members of RxCheck states indicated concern that the end-to-end security requirement would not be maintained. NABP staff stressed that these types of transactions occur millions of times per day and that the proxy service would not put the data at any more risk than it is now. The service would still use the transport layer encryption. Normal PMP transactions utilize Secure Socket Layer (SSL) encryption, with no message layer encryption. This concept is not only a step to help communicate hub-to-hub, but is also a way to deploy rapid integration. Open Networks and Health Information Design, Inc, have introduced an alternate concept to the proxy service recommended by NABP. In this proposed concept, the RxCheck state creates an NABP InterConnect message, puts this message into NABP InterConnect encryption, and takes the extra step of placing RxCheck encryption around the already encrypted InterConnect message. The message then moves to the proxy, which strips the message of the RxCheck security, and keeps the NABP InterConnect security as the message moves to the states. This triple encryption method is not necessarily how the translation needs to function, but some states have requested this alternate process. In reality, through this alternate concept, the RxCheck states are actually producing an NABP InterConnect message. The states have also asked BJA for a detailed technical specification on this new concept, but have not yet received the document. Discussions regarding the PMIX architecture continue due to the need to protect grant funding for the states; however, it is important to look at the other aspect of how this will

4 evolve and how the hub-to-hub communication and integration will be facilitated in the future. It remains to be seen how relevant the PMIX architecture will be down the road, but its evolvement is left to the discretion of the Alliance of States with Prescription Monitoring Programs. NABP staff explained that the ongoing discussions with BJA regarding the PMIX architecture also involved the Steering Committee chair in order to ensure representation of the Steering Committee. Staff stressed that the alternate solution developed by the software vendors was at this time just a proposal and that NABP has reached out to BJA to see if BJA is able to assist in funding for the development of the requested technical specifications for the alternate concept. On Boarding Discussion: Droz reintroduced herself to the Steering Committee and explained that one of the first things she was going to be focusing on was the onboarding document the states complete in order to share information with other state PMPs. She explained that she found some of the questions to be interpreted differently by each state. Droz plans to review all of the forms and talk to each member in order to understand exactly how each question was interpreted. From this information, she will tweak the form in order to ensure the questions are asked in a clear manner. This information is not only important for NABP InterConnect communication, but for the new PMP software to be rolled out in July. It is better to gather all of the information on the PMPs to document what they all do. This serves as an opportunity to sell the message that all the states are a lot more alike than they are different. Droz stated that she would be in touch with the states in the near future and plans to have more items to bring back to the Steering Committee at the summer 2013 meeting. In the meantime, Droz told the members to feel free to get in touch with her via or phone. Discussion ensued regarding role reconciliation. As Appriss works on the new PMP software, it has become apparent that more information is needed about what the PMPs are looking for. For example, confusion arose during one of the pilots when the vendor hard-coded the prescriber role only for Other Prescribers but did not recognize the role of MD/DO. In addition, some states may want to use Other Prescribers for optometrists and psychologists and other states may want to use it for naturopaths and optometrists, but do not recognize psychologists. In order to assist with the communication, it is necessary for all the states to use the same list of roles and provide specifics. Wright expressed the thought that Appriss was already expanding the roles so that they can check off all the different roles while logged into NABP InterConnect. Orr explained that this was correct, but that the software that some states are using cannot drill down to the same specificity and more research would need to be completed. Fontenot referenced an issue with roles as they pertain to physician assistants. It was expressed that this goes back to the idea that the states are very similar, but also have differences. The PMPs need to look at how they assign delegates and clarify this. Wright also added that the PMPs need to work out the differences. Droz explained that Appriss

5 and NABP are working to expand the roles to include dentists, nurse practitioners, optometrists, psychologists, naturopaths, etc. The ultimate key to all of this is that the software vendors need to accommodate and reconcile these roles. Droz s planned follow ups with the states will assist to inform NABP and Appriss of what is necessary in the role expansion in addition to what the states will need to communicate directly to the software vendors regarding this. Integration Projects: NABP staff began the integration projects update by explaining that they planned to reach out to the states about specific integration projects utilizing NABP InterConnect, NABP InterConnect and NARxCHECK, and just NARxCHECK, and also encouraged the states to contact staff should they have an idea about an integration project. Staff stressed that this will assist in prioritizing projects. As NABP InterConnect has been used to integrate data into the workflow through initial pilots, additional pilots, and longer term projects, NABP is finding that there is a lot of overlap between health care and the PMPs. To provide a little background, NABP staff broke down three main groups of potential integration partners: electronic medical record (EMR) vendors, electronic prescribing systems, and content providers. (At this time, Orr had to leave the call due to a fire drill.) Electronic Medical Record Vendors (eg, Cerner or Epic two of the largest in the country) Doctors frequently use EMRs in lieu of paper charts. In some cases the data may be hosted by the vendor; sometimes the data is maintained on site. The electronic medical record is the closest point to the prescriber where PMP or NARxCHECK data could be provided. Electronic Prescribing Systems (eg, DrFirst) Vendors of electronic prescribing systems may simply provide software or may partner with EMR vendors to provide the prescriber interface and medical activity. Thus, the doctor may have a single sign on to access the e-prescription system as well as the electronic medical record, or he or she may not. Content Providers (eg, Health Information Exchange (HIE), Immunization Data Provider, Medical History Provider) Content providers supply additional data to the EMRs and prescribers. With content providers, an audit trail and authentication are necessary. PMPs fall under the category of content providers, as would HIEs or immunization data providers. Staff explained that they were still working to understand how all of these groups work together and/or compete with each other. During the September meeting, the Steering Committee discussed the opportunity of having a non-pmp node or entity connect to

6 NABP InterConnect as a way to integrate their network. In this capacity, the PMPs would be providing additional content. At the direction of the Steering Committee, NABP moved forward with discussing the concept, identifying possible pilots with intermediaries, and discussing the parameters necessary to move forward. NABP explored connecting intermediaries to NABP InterConnect in order to rapidly integrate the PMP data, with no secondary use or access to the data. It was discussed that the data would only be delivered to the end user for digestion and that it would be provided in a format that no other intermediary would be allowed to access or store. As discussed by the Steering Committee, NABP would perform the translation and there would be no other opening of the envelope as messages move through the network. NABP staff reconfirmed with the Steering Committee that there was no reason to explore alternate methods of delivering this data other than what was just discussed, or any reason to change this type of approach to have other intermediaries link in. It was confirmed that data intermediaries would connect their network to make the request. NABP would handle all data and put the information in the format necessary for the end user to read the message. The direction remains that data intermediaries are to have no access to the message when it passes through their network or at the end point. The Steering Committee unanimously agreed that NABP could perform the translation and that there was to be no secondary use (such as collecting, copying, translating, or selling) of PMP data. After reconfirming the Steering Committee s position on no intermediary access to PMP data, NABP staff described other use cases including one with DrFirst, an EMR and e- prescribing company involved in two MITRE pilots. The pilot is now multistate, with DrFirst interested in a next wave of heavy deployment to other NABP InterConnect states. NABP will be reaching out to specific states, but welcomes any PMP to approach staff if interested in this pilot. The pilot with DrFirst would require very little adjustment from a technical perspective for the states. Another potential integration project includes one with Cerner, one of the largest EMR providers in the United States. Staff participated in a meeting in early April where Cerner expressed that they were highly interested in integrating PMP data into their work flow. Staff explained to the Steering Committee that Cerner appears to have the best audit trail and authentication setup they have seen to date in addition to their significant motivation. As background, staff shared that Cerner had participated in ONC pilots in the past with Kansas and Oklahoma PMPs. As with the DrFirst pilot, specific states have been identified as potential participants in a pilot with Cerner, but NABP encourages all states that might be interested to contact staff. Morris vouched for Cerner from her experience in an earlier pilot with the electronic medical record provider. She stated that she was confident in moving forward with any collaboration with them. As an outcome from the April meeting, Cerner expressed their desire to move forward quickly with integration, indicating that they would like to pilot as soon as fourth quarter 2013.

7 In wrapping up the discussion on the formal agenda items, staff reemphasized that they would be reaching out to those states currently connected to NABP InterConnect, those soon to connect, and those working toward a connection. In addition, it was mentioned that there may be another opportunity in the future through ONC relating to the Substance Abuse and Mental Health Services Administration (SAMHSA) grants. Staff emphasized that in communicating with ONC, SAMHSA, and Centers for Disease Control and Prevention, the previously mentioned integration projects are highly valued in the federal sector and a main point of focus. These federal organizations have expressed their excitement in integrating PMP data into the health care workflow. Morris shared that she was currently in the process of reallocating some of her grant funds to an integration project. In response, NABP staff mentioned that they are happy to assist any PMP with their grant adjustment notices or applications. Prior to the conclusion of the call, Hardy asked if staff could provide additional information on the Appriss project mentioned earlier. NABP staff explained that the NABP Executive Committee approved NABP moving forward with providing PMP software to five states at no cost for a period of three years. Committed states for 2013 include Kansas (scheduled to launch July 1), Mississippi, Nevada, Indiana, and Idaho (in no particular order). It is hoped that they will be able to add additional states in the future. The software will most likely be available for purchase; however, it remains NABP s goal to provide high quality products and services to the boards of pharmacy and the state PMPs at no charge. The conference call ended with a reminder of the upcoming 2013 summer in-person Steering Committee meeting. It is anticipated to last two full days at the end of July or beginning of August.