Compliance Review Fact Sheet | WI Controlled Substances Board

What is the Wisconsin Controlled Substances Board, and why does it conduct compliance reviews?

The Controlled Substances Board (CSB) is a multidisciplinary group of government officials and healthcare experts established in the Department of Safety and Professional Services under Wisconsin Statute 15.405(5g) to oversee the management of drugs with the potential for abuse or safety concerns. More information about the CSB is available on the Controlled Substances Board webpage, including members, meeting schedules, agendas, statutes and administrative codes.

How does the CSB use PDMP data for compliance review?

The CSB reviews various data points in their entirety to determine whether additional screening is appropriate. There are three primary types of information derived from the Enhanced PDMP database (ePDMP) that the CSB uses to review prescribing practices on a quarterly basis.

1. Dispensing Records: Individual practitioners whose opioid prescribing is among the top 0.5% by license type (MD/DO, PA, APNP, and Dentist) are identified for initial review. If less than fifteen opioid prescribers make up the top 0.5% for a certain license type, the top fifteen prescribers of the license type will be identified for initial review.

   CSB reviews analytics of dispensed monitored drug prescriptions issued by the practitioner, including types of medications most frequently prescribed, number of opioid patients, and prescribing percentile ranking relative to peers in the same specialty.

2. Concerning Patient History Alerts: CSB reviews the number of data-driven alerts associated with patients to whom the practitioner prescribed monitored drugs during the quarter, such as the Daily High MME and Concurrent Opioid and Benzodiazepine Prescriptions alerts. Data-driven alerts are derived from all dispensations not limited to prescriptions issued by the practitioner.

3. WI ePDMP Usage: CSB reviews the usage compliance of the practitioner. Practitioners are required to consult a patient’s ePDMP records prior to issuing a monitored drug prescription order to the patient unless the circumstances satisfy any of the exceptions provided by 961.385(2)(cs)2. The ePDMP Usage is a basic calculation of the number of ePDMP patient queries, including queries completed by a delegate of the prescriber, divided by the number of the dispensed monitored drugs prescribed by the practitioner.

Prescription orders for a 3-day supply or less are excluded from the PDMP usage calculation, but the calculation does not capture all exceptions of WI ePDMP usage (defined by Wis. Stat 961.385(2)(cs)2) nor scenarios such as multiple dispensations prescribed for the same patient on the same day, refills, or alternative workflows for WI ePDMP patient queries.

What data in the PDMP that the CSB uses for compliance reviews is available for practitioners to monitor their own practices?

Many of the features available in the WI ePDMP for prescribing Healthcare Professional Account users are dynamically updated daily, on a 100-day rolling basis. They are meant to provide information for self-evaluation as described below.

1. Dispensing Records: “Prescribing Practice Metrics” provides information about the practitioner’s own prescribing practices and how they compare to others in the same specialty broken down by drug classifications, in addition to summaries of patient alerts and prescription order details. Practitioners who have not reviewed their metrics in the past 100 days will see a pop-up reminder at log in.

2. Concerning Patient History Alerts: “Patients Panel” contains a snapshot of vital information about patients to whom the practitioner has recently prescribed a monitored drug. Data-driven concerning patient history alerts are displayed if present, in addition to drug related incidents submitted by law enforcement for interdisciplinary communication and treatment plans or overdose alerts submitted by practitioners to coordinate care.

3. ePDMP Usage: “ePDMP Usage” allows users to quickly and efficiently review their own and their delegates’ use of the ePDMP within a specified timeframe to ensure compliance with laws and healthcare system policies.

How can a health organization help or coordinate with practitioners to monitor their prescribing practice?

Health systems or facilities that wish to coordinate, direct, or monitor prescribing practices at the organizational level may do so via the Medical Coordinator role in the WI ePDMP. Medical Coordinator is a person who:

1. Medically coordinates, directs, or supervises a practitioner;

2. Establishes standard operating procedures for a practitioner;

3. Evaluates the job performance of a practitioner; OR

4. Performs quality assessment and improvement activities, including outcomes evaluation or developing clinical guidelines.

The information available to the Medical Coordinator is based on the past 100 days of dispensing records without patient identifiable information. More detailed information about the account type is available in the Wisconsin Medical Coordinator User Guide.