From: Cook, Jacqueline
Sent: Thursday, January 30, 2020 9:50 AM
To: Thanassi, Wendy <Wendy.Thanassi@va.gov>
Cc: Tacoronti, Rudolph V. <Rudolph.Tacoronti@va.gov>
Subject: RE: [EXTERNAL] Re: [MCOH-EH] Accessing state PMP for safety sensitive job applicants and DOTs
Hi Wendy,
Yes, this is a good point to mention. This is true of most states – state prescription monitoring program (PMP) laws and regulations conventionally restrict access to
treating healthcare providers. There have been cases (including to the level of the Supreme Court) in which individuals were convicted of PMP misuse as the individuals queried were not patients of the PMP user. With agency-directed medical examinations
such as fitness-for-duty examinations or pre-placement examinations, recall that these individuals under these specific circumstances indeed are not patients, as there is not a
treating provider-patient relationship, and so it is recommended not to use state-based PMPs to query prescriptions in these cases.
PMP misuse has been a concern in the MRO world as well. MROs have used PMPs to verify prescriptions, and again, it is recommended not to do so as the MRO can be accused of PMP
misuse.
HHS cites in the MRO Manual,
“A prescription may be verified by means such as:
·
Photos sent by text, e-mail, or fax showing enough angled shots of the bottle label that the MRO can verify the name of the donor on the label, prescription number,
name of the drug, prescribing physician, date filled, number of pills in the prescription, number of refills, and the pharmacy name, address, and contact information.
·
A verification call to the pharmacy (after the MRO has verbally obtained the information in the item above from the donor and documented it on the MRO record).
·
A copy of a pharmacy printout showing the medication dispensing history.
·
A signed statement from, or phone discussion with, the prescribing physician. In all cases, the MRO should verify that the contact was with the prescribing physician.
For example, the MRO may request the DEA number or state license number. For additional security, the MRO may obtain the physician’s telephone number from another source (e.g., online search) and call the individual to verify identity.”
Jacqueline M. Cook, MD, MPH, FACOEM
Medical Advisor, Office of Occupational Safety, Health and GEMS Programs (10NA5B)
VHA Central Office MRO Consultant/Headquarters MRO
Assistant Professor, Yale University School of Medicine
Tel: (203) 932-5711 x7749; Fax: (203) 937-4885
E-mail: jacqueline.cook@va.gov;
jacqueline.cook@yale.edu
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From: Thanassi, Wendy <Wendy.Thanassi@va.gov>
Sent: Wednesday, January 29, 2020 6:47 PM
To: Cook, Jacqueline <Jacqueline.Cook@va.gov>
Cc: Tacoronti, Rudolph V. <Rudolph.Tacoronti@va.gov>
Subject: FW: [EXTERNAL] Re: [MCOH-EH] Accessing state PMP for safety sensitive job applicants and DOTs
Hi Jackie,
I thought maybe you’d be interested in weighing in..
I’ll be in CT the first week of March. Let’s get a meeting on the books!
Wendy
From: MCOH-EH <mcoh-eh-bounces+wendy.thanassi=va.gov@mylist.net>
On Behalf Of Natalie Hartenbaum
Sent: Wednesday, January 29, 2020 2:29 PM
To: MCOH-EH <mcoh-eh@mylist.net>
Subject: [EXTERNAL] Re: [MCOH-EH] Accessing state PMP for safety sensitive job applicants and DOTs
This is the way it is for MANY states. There is actually RISK for OM providers checking the PDMP to evaluate routine fitness for duty, even in safety sensitive positions. Essentially if doing so, should do so for ALL applicants/employees.
If being asked to evaluate FFD because of OBSERVED findings, then it is reasonable to contact ALL treating providers and ask them to review the PDMP and work WITH you in evaluating FFD.
Natalie P. Hartenbaum, MD, MPH, FACOEM
President and Chief Medical Officer
OccuMedix
PO Box 197
Dresher, PA 19025
215-646-2205
occumedix@comcast.net