On March 7th 2016 GPDOTS wrote the Nova Scotia Minister of Health & Wellness , College of Physicians & Surgeons , and the Prescription Monitoring Program regarding our concerns with the programs ability to identify over prescribing. Shortly after our letter Minister Leo Glavine announced he would be ordering a full review of the program. The letter is as follows:
As you know in May 2012 the Auditor General released a report on the Nova Scotia Prescription Monitoring Program. The report contained numerous concerns and noted many deficiencies within the program. The report opened with “While some aspects of the Nova Scotia Prescription Monitoring Program are effective, there are significant weaknesses in the Program’s control and monitoring processes that can allow abuse or misuse of prescription drugs to continue undetected. Improvements are needed to address these issues.” A small portion of the concerns referenced included:
- Lack of consistency – The Auditor General’s office analyzed the data from the drug utilization reports during the audit period and found there was no consistent pattern to the situations for which letters were sent. They identified many instances in which a letter was sent when someone was one to two percent over the threshold; conversely, there were also many instances in which letters were not sent when an individual was prescribed 10 to 20 times the dosage threshold. While Program staff were able to provide possible explanations, there was no documentation to confirm this was the rationale considered when the cases were reviewed. Given these inconsistencies and the absence of any documentation supporting why cases were identified for follow-up, it is impossible to know whether all situations were followed up or whether the action taken was appropriate.
- Enforcement processes – The Program may send letters to prescribers following the review of a drug utilization report. Prescribers are required to provide a response. The Program’s medical consultant may also contact prescribers to discuss the specifics of a situation or may request additional information. If the prescriber does not reply before the deadline, a second letter is sent. If a response is still not provided, a final letter is sent indicating the matter will be referred to the College of Physicians and Surgeons of Nova Scotia if a reply is not received. The Auditor General’s office tested 24 initial letters to prescribers and identified three instances in which the file was closed even though the prescriber failed to respond to letters from the Program. While additional evidence may dictate a case can be closed, it is important the Program require all prescribers to respond to its requests for information. The Program should also document decisions made in these cases.
- Timeliness of medical consultant review – The sample selected from drug utilization review reports included three cases which were referred to the medical consultant for review. While all three situations were reviewed, there is no evidence of when the review was actually completed. The review results were entered in the Program’s system between 44 and 92 days after the initial referral to the medical consultant. The contract with the medical consultant establishes review timeframes of between seven and 30 days, although Program management told the Auditor General’s office these deadlines are not used in practice. Timely review by the medical consultant is important to address potentially inappropriate prescribing practices and prevent misuse or abuse of monitored drugs from continuing for longer than necessary.
- Thresholds – Currently, both drug utilization review and multiple prescriber reports are very large. The drug utilization review reports averaged 2,000 situations identified as exceeding thresholds; only 2% of these cases resulted in letters to prescribers and further analysis. The multiple prescriber reports averaged 215 situations identified, with notification letters sent in 13% of these cases.
February 24th, 2016 we learned various charges were laid against Dr. Sarah Jones practicing in Tantallon Nova Scotia. Those charges included trafficking Oxyneo and Oxycodone. Reports allege 50,000 pills were prescribed to a single patient then diverted by Dr. Sarah Jones over 20 months.
On March 2nd 2016, former Auditor General Michael Pickup was interviewed and stated as of June 2015, thirteen out of the seventeen Auditor Generals recommendations had been implemented. Some of the recommendations that have yet to be implemented relate to the concerns listed above in this letter.
Due to the severity of Dr. Jones trafficking allegations and the Auditor General’s recommendations that have yet to be fulfilled almost four years later GPDOTS would like to request the following information from Nova Scotia Prescription Monitoring and its partners cc’d in this letter:
- Did the extremely large quantity of medication that Dr. Jones allegedly prescribed and diverted alert the Nova Scotia Prescription Monitoring Program by raising red flags? What action did the program take if alerted?
- Were there any letters from the Nova Scotia Prescription Monitoring Program or the College of Physicians & Surgeons sent to Dr. Jones following the review of drug utilization reports?
- Did the Nova Scotia Prescription Monitoring Program alert the Nova Scotia College of Physicians & Surgeons at any time before a pharmacist called PMP about Dr. Jones’s prescribing? If so, did the College contact or have any follow up with Dr. Jones?
- What corrective actions do your organizations plan on taking to prevent future negligence and over prescribing?
Get Prescription Drugs off the Street Society (GPDOTS) is committed to creating awareness, education, and most importantly accountability when it comes to the prescription drug use epidemic. In order to prevent future diversion and encourage responsible prescribing there needs to be an understanding of how such a large amount of controlled drugs could be prescribed for 20 months without intervention. GPDOTS would like to encourage the Nova Scotia Department of Health & Wellness to seriously consider executing a full review of the Nova Scotia Prescription Monitoring Program and fast track the implementation of any outstanding Auditor General recommendations.
We look forward to hearing from your various organizations as we piece together how such a shocking amount of dangerous medication could make it from a prescription pad to the street without intervention for so long.