Minnesota Statute 256B.0638 requires the Department of Human Services to provide individualized opioid prescribing reports to all health care providers who prescribe opioids for pain management to Minnesotans enrolled in MinnesotaCare or Medicaid. Providers who prescribed at least one opioid analgesic in an outpatient setting to a Medicaid or MinnesotaCare enrollee during the measurement period will receive a report. This includes providers who prescribe to fee-for-service members and those who care for members enrolled in a managed care organization. The initial reports were sent in summer 2019 with an updated report issued in December 2019. The next round of reports will be sent in late 2020 and annually thereafter.
The data in each report is from Medicaid and MinnesotaCare administrative claims data. This means that only data on Medicaid and MinnesotaCare patients is included in the DHS prescribing reports. The opioid prescribing reports exclude individuals who received a cancer diagnosis or treatment in the measurement year and individuals receiving hospice services. The reports also exclude medications prescribed to treat opioid use disorder. All other Medicaid and MinnesotaCare members for whom DHS receives a pharmacy claim are included, including children and individuals with both Medicaid and Medicare coverage.
No. Under Minnesota Statute 256B.0638, the opioid prescriber reports are confidential to individual prescribers. The law permits DHS to notify a provider’s affiliated practice if the provider is required to participate in the quality improvement program, but that will not happen until late 2020.
Yes. Prescriptions for patients with a cancer diagnosis or treatment in the measurement year and patients who received hospice services are excluded. Medications used to treat Opioid Use Disorder are not included in the analysis. Procedural sedation or anesthesia and medications administered in an emergency department or from an inpatient pharmacy are also not included.
All providers who prescribed an opioid analgesic to a Medicaid or MinnesotaCare enrollee in an outpatient setting will receive a report. A provider would not receive a report only if they did not prescribe an opioid analgesic to a Medicaid or MinnesotaCare enrollee or if they only prescribed to patients whose data are excluded from the reports.
No. All data in the reports is presented in aggregate form and does not identify specific patients or their prescriptions.
The reports compare providers’ metrics to the average rates within their specialty group. DHS used the National Plan and Provider Enumeration System (NPPES) database to locate providers’ National Provider Identifier (NPI) primary taxonomy code. Providers are included in one of 30 specialty groups based on their NPI primary taxonomy code.
To update your specialty listing, you must do both of the following.
A special note to Physician’s Assistants and Advanced Practice Nurses (APNs): The NPPES system and DHS provider enrollment data do not include a comprehensive list of specialty designations for physician’s assistants and APNs. Therefore, many physician assistants and APNs are included in a general category in the reports. DHS recognizes that many physician assistants and APNs practice in specialty settings and DHS will collect correct specialty data from these providers in early 2020.
The specialty designation influences the thresholds only for those in surgical practice. In all other cases, the QI thresholds do not vary by specialty. Providers whose specialty designation is not accurately reflected on their report can still obtain the comparative data for their correct specialty by emailing email@example.com.
How do the QI thresholds vary for surgery?
Will the thresholds vary over time, as prescribers change their practices?
The quality improvement thresholds are static. The requirement for quality improvement will depend on the DHS threshold, not on how a provider compares to their specialty peers. As prescribing trends downwards, DHS will not change the QI threshold unless advised to do so by its clinical advisory body.
The DHS report is part of the Opioid Prescribing Improvement Program — a quality improvement program required by statute within the Minnesota Health Care Programs (Medicaid). DHS’ report includes only prescription data for MHCP members and is limited to opioid therapy for pain management. The Minnesota Board of Pharmacy reports include all controlled substances prescribed by a provider, regardless of the patient’s health insurance.
DHS uses administrative claims data within the reports. DHS is confident the data underlying the reports is accurate, and also recognize that the primary purpose of the data is for billing purposes. Therefore, there are instances when a pharmacy or medical claim may be linked to an organization or consolidated NPI number, rather than an individual.
It is important to keep in mind that the data is only for MHCP members who received an outpatient opioid prescription. Therefore, it is likely that the data underrepresents the scope of your opioid prescribing. Providers who wish to review all of their prescribing data, may do so in the Prescription Monitoring Program (PMP).
Those interested in a more detailed description of DHS’ methodology may email firstname.lastname@example.org.
A new state law requires all providers authorized to prescribe opioids to take continuing education. OPIP participants are exempt from this continuing education requirement. See Minnesota Statute 214.12, subdivision 6. Providers are considered an OPIP participant if they received an opioid prescriber report from DHS in the summer of 2019 or a report dated December 2019.
Summer 2019 – DHS issued a first round of prescriber reports to roughly 16,000 MHCP prescribers. The data referenced in these reports was from prescriptions written between January 2018 and December 2018. No quality improvement was required with the summer 2019 reports.
December 2019 – DHS issued a second round of prescriber reports to roughly 16,000 MHCP prescribers. The data referenced in these reports was from prescriptions written between September 2018 and October 2019. No quality improvement was required with end-of-year 2019 reports.
Fall 2020 – DHS will issue another round of reports late in 2020. Providers over one or more quality improvement thresholds at this time may be required to participate in the state’s quality improvement program. At this point providers as well as their employers will be notified about the mandatory participation in quality improvement.
Participation in the OPIP quality improvement program will be based on two factors:
Don’t stop! DHS will work with providers and health systems with existing quality improvement programs to avoid duplicative efforts. DHS, the Opioid Prescribing Work Group and partners in the medical community are currently developing the quality improvement program and will share information about the quality improvement process as it is developed.
No, the statute does not exempt any provider from participation. However, DHS recognizes that there are providers whose practice involves high rates of opioid therapy, or who care for highly vulnerable patients on long-term opioid therapy. DHS is working with the medical community to understand how QI applies to these providers.
No. Please do not drop your patients or abruptly change their care. If a change in your patient’s opioid therapy will harm a patient, then do not do it. The quality improvement program is intended to be a collaborative process through which providers gain access to resources that will help them make proactive improvements to opioid prescribing behavior, if needed, and to navigate their relationship with complex, high-risk patients.
DHS is committed to supporting providers and ensuring patient safety. DHS is currently designing the quality improvement program with significant input from the medical community to reduce unintended consequences for patients and providers.
Tapering opioid therapy can be challenging for both the patient and the provider. The current medical evidence indicates that tapering successfully improves a patients’ risk profile, but that taper regimens must be individualized to the patient’s unique needs and circumstances. General guidance is provided on the Minnesota Opioid Prescribing Guidelines webpage, but it is only intended to serve as a starting point.
Additional resources for learning how to safely taper patients include:
Providers are strongly encouraged to sign up for email updates from DHS which will provide quick, timely updates on the quality improvement program.
Participation in the quality improvement program is based on the prescribing reports that will be released late in 2020. Providers whose prescribing rate is above the rate and volume thresholds for any of the five measures must participate in the quality improvement program. Both prescribers and their health systems or provider groups will be contacted in the event they are identified for quality improvement.
The exact framework of DHS’ QI program has not been finalized. DHS, the Opioid Prescribing Work Group and partners in the medical community are currently developing the quality improvement program. The intent is to identify a set of required activities—based on pain phase—that a provider would incorporate into their quality improvement plan. DHS will consider quality improvement programs a provider might already be doing. Sign up for email updates to receive QI information from DHS once the program has been finalized.
Yes, because DHS understands that tapering patients from high-dose, chronic opioids should be done slowly and gradually. The quality improvement efforts related to measures on chronic opioid analgesic therapy will focus on harm reduction, provider education, peer consultation and risk assessment.
DHS is also aware that providers may inherit significant numbers of chronic pain patients, for example, when a pain specialist in their geographic area retires. Factors like this will be considered.
Yes, providers who treat patients with very severe, acute pain will be considered for special exemptions. Information about how to request an exemption will be announced closer to the beginning of the quality improvement program. In addition, surgical specialties are exempt from quality improvement based on their prescribing rate for Measure 1 (Percent of enrollees prescribed an index opioid prescription).