- Why did NABP develop PMP InterConnect?
- How was NABP PMP InterConnect developed?
- What is the process for connecting to the NABP InterConnect?
- How much does the NABP InterConnect cost?
- How is the NABP InterConnect being funded?
- What happens after the five years of funding?
- What about cost for amending PMP software in order to connect to the NABP InterConnect?
- How is the NABP InterConnect being governed/administered?
- Will users of the NABP InterConnect need to enter in to an individual MOU with each state PMP in order to communicate?
- How long is a PMP locked in to using the NABP InterConnect once an MOU is executed?
- Does the NABP InterConnect offer customer and technical support?
- Do the InterConnect and NABP offer education to practitioners, pharmacists, and other users of PMPs regarding interstate data sharing and the NABP InterConnect?
- Will users of the NABP InterConnect be responsible for recoding or reconfiguring software in order to communicate with other PMPs?
- Will users of the NABP InterConnect be responsible for maintaining security certificates for each PMP with which they want to communicate?
- Will states using the NABP InterConnect also be able to connect to other states using a different interconnect solution that may become available in the future, such as the “BJA (PMIX) hub,” without having to support interfacing with the other solution?
Will PMPs that received Harold Rogers Prescription Monitoring Program Grants that specify “PMIX” be able to use those monies toward the NABP InterConnect?
Recognizing NABP’s background in assisting boards of pharmacy and other regulators in protecting the public health, NABP was approached by several prescription monitoring program (PMP) administrators in the fall of 2010 about building an effective, easy to implement, and highly enhanced solution for interstate data sharing that could be implemented in under a year.
The NABP InterConnect was developed using a consensus-based process involving PMP administrators from across the country. The development began in January 2011.
The administrators made several specific requests of the NABP InterConnect design and function:
- Utilize the messaging specification that was an outgrowth of the Bureau of Justice Assistance (BJA) efforts with the Prescription Monitoring Internet Exchange (PMIX), which would allow for seamless communication of program information between PMP programs;
- Encrypt the requests and responses from PMP to PMP using highly secure, widely-deployed encryption technologies, ensuring no Protected Health Information or Personally Identifiable Information is exposed to any entity other than the disclosing and requesting PMPs;
Design the InterConnect solution as follows:
- Built using open standards
- Cost effective
- Easy to implement
- Low maintenance
- Include a rules engine that would allow PMPs to maintain complete control and autonomy over PMP data exchanges with other states participating in the NABP InterConnect.
- The NABP InterConnect, which launched for nationwide use on July 27, 2011, has effectively met and in many cases exceeded each of the criteria and expectations set by the PMP administrators.
There are two major steps necessary in order to “connect” to the NABP InterConnect:
1. Execute a single memorandum of understanding (MOU) (PDF).
- NABP’s legal team is available to build any necessary state-specific language into the MOU. This includes state boilerplate contracts and other necessary addendums and attachments.
- Further, NABP’s legal team is available to work directly with the appropriate state legal contacts at the relevant state agency, or with the Attorney General’s office.
2. Build an interface to “connect” to the NABP InterConnect.
- PMPs that utilize Optimum Technology or Health Information Designs for PMP software should contact their vendor to “order” the NABP InterConnect interface. Both vendors have the appropriate interface available for their customers.
- PMPs that utilize an in-state vendor or a state IT department should provide the PMP InterConnect Application Programming Interface (API) to the relevant programmer/individual.
- NABP and its technology solution provider, Appriss, Inc, is available to assist states in building the appropriate interface, and to provide ongoing technical support and training.
NABP is paying for all costs associated with the development and implementation of the NABP InterConnect, as well as a minimum of five years of annual participation fees for each participating PMP.
NABP is exclusively using its own resources, derived from program revenues, to fund the development, implementation, maintenance, and five years of annual participation fees for each participating PMP. NABP has the financial resources to make this commitment without the need for any outside funding sources.
While it is NABP’s intention for states to never have to pay to participate in PMP InterConnect, at the end of the fourth year of funding, NABP will evaluate and notify the states of the funding status for years six and seven. NABP will continue to provide timely cost estimates for participating PMPs if NABP is unable to continue to fund the entire cost of the program.
The NABP Foundation received a $1 million grant from Purdue Pharma L.P., which is being made available to states that need assistance in paying for the appropriate interface or software changes in order to participate in the NABP InterConnect, and that can accept such funding.
Although not restricted by Purdue in any way, the NABP Foundation has determined that this grant will not be used for any costs associated with the development, implementation, or ongoing operational costs of PMP InterConnect. This grant will be administered through the NABP Foundation, a separate non-profit charitable organization. Funds held by the NABP Foundation are used for special educational or public safety projects that are separate from and outside NABP’s core programs and activities. Additionally, no grantor has any access to, influence, decision-making authority, or consideration relative to the NABP InterConnect and its administration and functions. As of October 10, 2011, the NABP Foundation has paid out $203,340 to state PMPs or their software vendors for purposes of connecting individual states via the NABP InterConnect.
The NABP InterConnect is governed by a Steering Committee, exclusively composed of representatives of the PMPs that are participating in the system. The Steering Committee serves as the governing and advisory body as it relates to the administration and function of the NABP InterConnect. No outside organization, public or private, has access to PMP InterConnect, a vote about, influence over, or the ability to direct the administration and function of the NABP InterConnect. Outside parties and subject matter experts may, however, be asked to provide information for the Steering Committee’s consideration from time to time.
9. Will users of the NABP InterConnect need to enter in to an individual MOU with each state PMP in order to communicate?
No. Only a single MOU, executed between NABP and the PMP itself is necessary to participate. The advanced functionality of the NABP InterConnect allows each state PMP to maintain complete control and autonomy over who accesses its data via the NABP InterConnect. However, if a state has specific legal or regulatory requirements that dictates that state-to-state MOUs must be executed, that state could still participate in the NABP InterConnect and take advantage of the functionality of the system.
NABP has similar MOUs in place with each state for services related to NABP’s other programs and services, and can easily adapt its MOU to meet state-specific requirements.
The MOU requires 30 days of written notification, if a PMP wishes to discontinue use of the NABP InterConnect. There are no fees or penalties associated with voiding the MOU.
Yes. NABP InterConnect offers customer and technical support services 24 hours a day, seven days a week.
12. Do the InterConnect and NABP offer education to practitioners, pharmacists, and other users of PMPs regarding interstate data sharing and the NABP InterConnect?
Yes. NABP is available to provide educational programming regarding the NABP InterConnect and interstate data sharing to a range of audiences, including PMP users, state and local law enforcement and state and local government.
13. Will users of the NABP InterConnect be responsible for recoding or reconfiguring software in order to communicate with other PMPs?
No. The functionality of the NABP InterConnect prevents each PMP from having to recode or reconfigure their PMP software when they want to share (or not share) with a participating PMP. Once the appropriate interface is developed, the PMP administrator, through simple clicks of a button, can determine which other participating PMPs they wish to communicate with via the NABP InterConnect.
14. Will users of the NABP InterConnect be responsible for maintaining security certificates for each PMP with which they want to communicate?
No. The NABP InterConnect interface includes all necessary security measures and does so behind the state’s firewall and according to each state’s security needs and requirements.
15. Will states using the NABP InterConnect also be able to connect to other states using a different interconnect solution that may become available in the future, such as the “BJA (PMIX) hub,” without having to support interfacing with the other solution?
Yes, if the PMP InterConnect participants wish to communicate with PMPs that may be connected to another “hub,” NABP will work to ensure that seamless, effective, and secure communications can occur with that other hub using PMP Interconnect.
16. Will PMPs that received Harold Rogers Prescription Monitoring Program Grants that specify “PMIX” be able to use those monies toward the NABP InterConnect?
Yes. According to correspondence from BJA on August 16:
“BJA recently released guidance on the use of Harold Rogers grant funding for the purposes of interstate data sharing. Assuming that the PMIX Architecture can be established through the process described above, BJA anticipates modifying its guidance and related funding special conditions to require that any supported interstate solution be PMIX Architecture compliant, meaning that funds could be used to support any hub solution that has been verified to implement the PMIX Architecture. This would apply to both PMPi [NABP PMP InterConnect] and PMIX Hub and any additional hubs designed and implemented in accordance with the Architecture. BJA will only permit funding to be used to support interstate solutions that enable nationwide connectivity, which by definition is the goal of the PMIX Architecture. Similarly, BJA will only offer training or technical assistance services for the purpose of interstate data sharing to agencies who are seeking to implement PMIX Architecture compliant solutions.”
NABP is currently participating in the discussions to establish the “PMIX Architecture.” As BJA is tying funding that may be used for interstate data sharing to only solutions that will be PMIX Architecture compliant, NABP wants to ensure that the funding of states participating in the NABP InterConnect is protected. As such, if the NABP InterConnect Steering Committee determines that it is important for the NABP InterConnect to become PMIX Architecture compliant, NABP will take the appropriate steps to do so.