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National Association of Boards of Pharmacy ® About NABP Formed in (c)(3) Charitable and Educational Organization 50 State Boards of Pharmacy, District of Columbia, Guam, Puerto Rico and the US Virgin Islands Mission: Assisting member Boards and regulators in Protection of the Public Health

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Page 1: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs
Page 2: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

NABP PMP Interconnect NABP PMP Interconnect

Conference of Western Attorneys Conference of Western Attorneys General General

July 13, 2011July 13, 2011

Joshua M. BolinGovernment Affairs Director

Page 3: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

About NABPAbout NABP

• Formed in 1904• 501(c)(3) Charitable and Educational

Organization• 50 State Boards of Pharmacy, District of

Columbia, Guam, Puerto Rico and the US Virgin Islands

• Mission: Assisting member Boards and regulators in Protection of the Public Health

Page 4: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Scarce ResourcesScarce Resources• Authority and Autonomy• Human and Fiscal

– Hiring Freeze– Work Furlough Programs– Budget Cuts

• Myriad of Mandates– Impairment Programs– Prescription Drug Monitoring Programs– Drug Repository

Page 5: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Patchwork of PMPsPatchwork of PMPs

• Different standards from state to state• Systems do not talk to each other• Users on border states have to become users

with each program in surrounding states

Page 6: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

NABP InterconnectNABP Interconnect

• Since the mid 2000s, sponsored by the Bureau of Justice Assistance, PMPs and other interested parties have been working toward a solution

• Last year, some of our membership came to us and asked us to try to take their work to the next level and create a system that would facilitate data sharing from state to state

Page 7: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Key System FunctionsKey System Functions

• NABP’s PMP Interconnect, or PMPI, has three core functions:• Transmit Request Between Various State PMP’s• Review for Disclosing PMP• Transmit Disclosed Response

• All Information is kept Secure:– Hosting – Authentication – Controlled Access –

Audits

Page 8: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

NABP InterconnectNABP Interconnect

• Does not house or store any Protected Health Information (PHI) or Personally Identifiable Information (PII)

• PHI and PII are doubly encrypted as it passes through the InterConnect

• Enforces the unique rules of each state against the request

• Allows the states to maintain control over the systems they worked so hard to get enacted and operational

Page 9: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Sample PMP Level Controls

Page 10: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Sample Role Authorizations

Page 11: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 12: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 13: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 14: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 15: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 16: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

The Disclosing PMP may:CompleteDeferDisallowMark as ErrorRefuse

Page 17: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 18: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 19: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 20: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Sample Response Report

Page 21: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Secure, HIPAA Compliant Data Secure, HIPAA Compliant Data

• All communication is secure • Asymmetrical Cryptography over SSL• Only the Requesting PMP will be able to view the

response

Page 22: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

MOU/Contracting ProcessMOU/Contracting Process• Programs will contract/enter into an agreement

directly with NABP to participate in the NABP Interconnect

• Avoids multiple state-to-state contracts/memorandums of understanding (MOU)

• Allows the hub to handle the “rules reconciliation”• NABP responsibilities vs. state responsibilities• States agree to conduct investigations for misuse

of information through the hub by their users• Dispute resolution • 30-day “out clause”

Page 23: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Timeline for ImplementationTimeline for Implementation

• Development is complete• NABP is now working with PMP software

vendors to complete the relevant interface• PMPs are beginning to configure their PMP on

the PMP Interconnect Administrative Console• PMPs will begin sharing data later this summer• More PMPs will be brought online in Q3-Q4

Page 24: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Cost to ParticipateCost to Participate

• NABP is absorbing all costs associated with the development and implementation of PMPi

• NABP will cover the costs of the Annual Base fee to participate in the system

• NABP will cover annual participation fees for utilization of PMPi for 5 years

• NABP will cover software interface costs associated with connecting to PMPi

Page 25: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

MOU UpdatesMOU Updates

• 9 MOUs Executed: CT, IN, KS, MS, ND, OH, SC, VA, WV

• 5 MOUs in final review stages: AZ, LA, MI, NV• 12+ other PMPs have expressed an intent to

sign on with PMP Interconnect

Page 26: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Page 27: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs

National Association of Boards of Pharmacy®

Josh BolinJosh BolinGovernment Affairs DirectorGovernment Affairs [email protected]@nabp.net(615) 804-8027(615) 804-8027www.nabp.net/government-affairswww.nabp.net/government-affairs

Page 28: National Association of Boards of Pharmacy ® NABP PMP Interconnect Conference of Western Attorneys General July 13, 2011 Joshua M. Bolin Government Affairs