Recommendations for Enhancements to ASAP PDMP Standard

Technical PDMP Reporting
1

From:
Theo Antoniou, CTO at MDScripts theo@mdscripts.com
Travis St.John, Chief Compliance Officer at Logicoy travis.stjohn@logicoy.com

We would like to recommend the following additions/changes to the ASAP format being used for controlled substance reporting. Please provide any comments or feedback.

1- Add “Product Description Field” to the end of DSP segment.
Reason: Too often data collection companies get an NDC (DSP 08) that is not in their database. This leads to a lot of work and communication with the submitter to determine what the Product ID Qualifier (DSP 07) and Product Id (DSP 08) represent. Having a product description with max 64 characters would allow data collection companies to easily add the missing products to their databases.

2- Add “Serial Number” to the end of the DSP segment.
Reason: As of Nov 2017, all pharmaceutical companies have been required to print the DSCSA GS1 barcode ( dot-matrix barcode) on their packaging. The barcode has a unique serial number for each product for upcoming DSCSA track and trace requirements that take effect Nov 2023. Having the serial number will enable the detection of diversion and counterfeits. While not many pharmacy software vendors are capable of storing and reporting the serial number, this will become a requirement in Nov 2023.

3- Add “State License” to the end of PRE segment
Reason: Many states are requiring the reporting of “Drugs of Concern” which are not DEA scheduled medications. Prescribers with no NPI or DEA number can prescribe Drugs of Concern since they are not a scheduled medication from the DEA. Having the state license field would allow the prescriber to be indicated in the prescriber (PRE) segment. The pharmacy (PHA) segment already has a state license field (PHA 13). The standard should indicate that in cases where the either pharmacy or the presciber do not have an NPI or DEA license, the state license fields are required to identify the entity dispensing or prescribing.

Thank you for your consideration.
-Theo/Travis

2

Theo/Travis,
Will either of you be attending the ASAP Mid-Year Conference in Boston as there will be a session and time to discuss sugesstions for fields, qualifers, etc.

3

Yes, I will be attending this conference.

Travis

4

Just found out about this conference. Looks like it would be $1950 to attend! Will have to think about it. They never reply to any of our emails.

https://asapnet.org/conference-registration/asap-2022-midyear-conference/

5

I would have thought MDScripts would be a member of ASAP so the company would have all the details of the format and the member price is lower. How does MDScripts obtain the ASAP format documentation, do you just pay each time to get the latest version. As a state never fully understood the process for software vendord to obtain the documentation.

6

ASAP gives the state the free Format. It’s then the responsibility of the state and their respective vendors to give it to software vendors, and dispensers to update the records.

7

States are not allowed to share with vendors or dispensers the format or the state will loose the free access. States can use to create data collection manual but if too much information about the format is provided the state can loose their free access to the documentation and have to purchase the documentation.

8

I understand that. However, the state must provider the data collection manual which is what the software vendors and all use to upload data. Typically we do not need any additional features.

9

MDScripts uses the information in each of the states’ dispenser guides to determine what needs to be reported to each state. It’s unfair that there’s a state requirement to report but the people have to buy something from a specific company in order to do meet that requirement.

Each state lists the ASAP fields in their dispenser guides but hides the max field size on just the text fields. The idea that people are going to join ASAP to get the max field sizes is unrealistic.