VA Health Care: Progress Made Towards Improving Opioid Safety, but Further Efforts to Assess Progress and Reduce Risk Are Needed
Released: 2018-05-29T00:00:00

Letter

Background

To help ensure that veterans are prescribed and use opioid pain medications in a safe and effective manner, VHA launched its OSI nationally in 2013. VHA established nine OSI goals in a December 2014 memorandum. For each of the goals, VHA directed its VISNs and their associated VHA medical facilities to take specified actions to meet the goals. (See table 1.)

VHA has also developed opioid risk mitigation strategies for its providers to follow when prescribing opioid pain medications to veterans. These key strategies include one whose increased use is an explicit goal for the OSI and two that are requirements in VHA policy. 1. Annual urine drug screening for veterans on long-term opioid therapy.

Providers should generally ensure that a urine drug screening has been conducted for veterans who are on long-term opioid therapy at least once in the 365 days prior to initiating or renewing an opioid prescription. Urine drug screening allows providers to monitor the types of drugs that are in a veteran’s system, including controlled and illicit substances. Increasing the use of urine drug screening is OSI goal two. 2. Annual prescription drug monitoring program (PDMP) query. PDMPs are state-run electronic databases used to track the prescribing and dispensing of prescriptions for controlled substances, identify suspected misuse or diversion (i.e., channeling drugs into illegal use), and identify trends in drug utilization. In 2016, VHA began requiring in policy that providers query state PDMPs at least once annually when prescribing opioids to determine whether their patients have received prescriptions for opioid medications or other controlled substances from non-VA providers. 3. Informed consent for long-term opioid therapy. In 2014, VHA began requiring in policy that providers educate their patients on the risks associated with the use of prescription opioids and to obtain veterans’ formal acknowledgment of these risks in writing prior to initiating long- term opioid therapy.

Clinical Practice Guidelines for the Treatment of Chronic Pain

In 2010, in coordination with DOD, VA developed clinical practice guidelines for its providers to use when prescribing opioids for chronic pain. These guidelines were updated in 2017. While clinical practice guidelines contain evidence-based recommendations, they are not required to be followed in all clinical situations; therefore, variations in practice may occur based on individual patient needs subject to the discretion of the provider.

The 2017 VA/DOD clinical practice guidelines related to opioid therapy for chronic pain generally complement VHA’s OSI goals. For example, the guidelines recommend a conservative use of opioids for chronic pain and emphasize strategies to mitigate the risk of using opioids. The evidence- based clinical practice guideline recommendations include the following: 1. Use of non-pharmacological treatments. The guidelines advise not initiating opioid therapy for chronic pain. They also recommend alternatives to opioid therapy, such as non-opioid medications and non-pharmacological treatments. Non-pharmacological treatments for chronic pain include, for example, cognitive behavioral therapy and yoga. 2. Naloxone prescribing. Naloxone is a highly effective, potentially life- saving intervention for reversing opioid overdoses, and it can be prescribed to veterans as a preventive measure. Veterans who are prescribed naloxone can use it when experiencing an overdose or a family member can administer it on their behalf. According to the clinical practice guidelines, naloxone should be offered as an antidote to all patients at risk for an opioid overdose, including those who are in the process of tapering from opioids. The guidelines describe several significant risk factors which can indicate the prescribing of naloxone, including the duration and dose of opioids, current or history of depression or substance use disorder, and suicidality. 3. Appropriate follow-up visits with a provider. According to the guidelines, follow-up pain management visits should be scheduled at least every 1-4 weeks after any change in medication regimen and at least once every 1-3 months for the duration of the therapy to help ensure that the treatment plan is optimized.

Under Its OSI, VHA Tracks Opioid Prescribing Patterns, Identifies Prescribing Outliers, and Educates Prescribers

VHA officials told us that the main focus of the OSI is changing the prescribing patterns of providers to better align with evidence-based practices. We found that this has been carried out by VHA through three key efforts: tracking opioid prescribing rates and other trends, identifying irregular prescribing patterns, and educating providers on best practices through academic detailing.

Tracking Opioid Prescribing Patterns. Under the OSI, VHA uses quarterly data derived from VHA’s electronic medical record system to monitor prescription opioid use among veterans, the related prescribing patterns of VHA providers, and the rates of urine drug screening for veterans receiving long-term opioid therapy. Specifically, VHA tracks the following four clinical indicators, known as the OSI metrics, for each of its medical facilities: 1. the percentage of patients dispensed an opioid, 2. the percentage of patients dispensed an opioid and a benzodiazepine, 3. the percentage of patients on long-term opioid therapy who received a urine drug screen within the previous year of having their prescription filled, and 4. the percentage of patients dispensed greater than or equal to 100 morphine milligram equivalents per day.

Our analysis of quarterly OSI metric data shows that since the beginning of the OSI in the fourth quarter of fiscal year 2013 to the first quarter of fiscal year 2018 (the most recent data available at the time of our review), the percentage of veterans dispensed an opioid has decreased by 7 percentage points, or roughly 267,000 veterans, while the rate of urine drug screening for veterans on long-term opioid therapy increased significantly—by over 47 percentage points. The increase in the percentage of patients receiving a urine drug screening was driven more by a reduction in the total number of patients on long-term opioid therapy (about 197,000 veterans) than an increase in the number of patients receiving the screening (about 27,000 veterans). (See table 2.)

Identifying Irregular Prescribing Patterns. As part of its monitoring of the OSI metrics, VHA Central Office has periodically identified VHA medical facilities and VHA providers who deviate from average prescribing rates across VHA. For example:

Facilities. In 2014, VHA Central Office identified 39 of 140 medical facilities across 12 VISNs with relatively higher rates of opioid dispensing as outliers based on the OSI metric percentage of veterans dispensed an opioid. VHA Central Office notified the VISNs of these facilities and required each facility to submit a corrective action plan to VHA Central Office outlining the actions they would take to reduce opioid prescribing. Based on our analysis of VHA documents, we found that the identified facilities in the five VISNs selected for our review submitted information in response to VHA Central Office’s request.

Providers. In February 2017, VHA Central Office identified 320 outliers out of 8,351 providers at 94 VHA medical facilities based on the relatively high proportion of their patients who were prescribed opioids. VHA Central Office directed the VHA medical facilities associated with these outlier providers to review their prescribing rates in the context of their clinical practice, and to report back with any feedback given or actions taken. According to officials from the five facilities in our review, outlier providers tended to be surgeons, pain management specialists, or physical rehabilitation providers who might be expected to prescribe opioids at a higher-than-average rate due to the nature of their specialty and the types of patients they treat. According to a VHA Central Office progress report, the facilities provided feedback and follow-up actions for 319 out of 320 outlier providers. In May 2017, VHA identified a second round of 303 outliers out of 8,505 providers; 187 of these providers were previously identified as outliers in February 2017. According to one VHA Central Office official, as of September 2017, VHA was reviewing these outlier data and will evaluate whether VHA facilities will be asked to conduct further reviews of these prescribers.

Educating Providers through Academic Detailing. To help change the prescribing patterns of providers, VHA has also implemented a system- wide academic detailing program to educate providers and improve the delivery of evidence-based health care at facilities. In 2015, VHA required each VISN to establish such a program to improve performance on all OSI metrics. According to VHA Central Office officials, academic detailers are responsible for reviewing facility-level data on the prescribing patterns of providers and identifying potential areas of improvement. Detailers can educate providers with higher-than-average prescribing rates—such as those outliers identified in February and May 2017 by VHA Central Office—to help ensure providers are delivering safe and effective care for pain.

According to VHA, as of January 2018, academic detailers have conducted over 20,000 opioid-related visits to VHA providers. According to VHA officials, their data also show that academic detailing results in greater patient safety for veterans taking opioids. For example, compared with those who did not receive academic detailing visits, providers who did receive such visits experienced (1) greater reductions in the proportion of their patients on high-dose opioids, (2) reductions in their patients’ average morphine milligram equivalent daily dosage, and (3) increases in their naloxone prescribing rates.

VHA Has Made Progress on OSI Goals, but Performance Measurement Limitations Exist for Some Goals and Certain CARA Provisions Have Not Been Fully Implemented

VHA Has Made Progress on Many 2014 OSI Goals, but for Some Goals, Performance Measurement Limitations Prevent an Accurate Determination of their Completion

Based on our analysis of VHA information, we found evidence suggesting that the agency has accomplished six of the nine 2014 OSI goals. For example, the agency has seen increases in the use of urine drug screening for veterans on long-term opioid therapy, and it has developed provider tools to identify veterans at a higher risk for adverse events while using opioids. For several goals, although VHA did not implement the actions required in all those instances, the agency provided us with information or data demonstrating that the goals had effectively been met. However, for three OSI goals, it is unclear if the goal has been fully met because VHA lacks documentation showing that it has implemented the required action under the goal or the required action is still in progress. (See table 3.) (See appendix I for a more detailed description of VHA’s known efforts and data related to each goal).

When asked about the lack of documentation for two of its OSI goals (goals four and seven), VHA officials told us that relevant documentation could not be produced. This lack of documentation is inconsistent with federal internal control standards. Specifically, according to federal internal control standards, management should evaluate and document the results of monitoring. By not documenting the actions it is taking under each of its OSI goals, VHA lacks assurance that these actions have been implemented by the VISNs or VHA medical facilities. As a result, VHA does not know whether it has fully met these OSI goals.

Moreover, for the OSI goal related to establishing safe and effective VISN tapering programs for veterans using opioids and benzodiazepines (goal four), VHA officials told us that they addressed this goal by issuing national tapering guidance, including a provider reference guide in 2014, an opioid taper decision tool in 2016, and the VA/DOD clinical practice guidelines in 2017. However, these actions do not appear to be sufficient for meeting the goal as it is currently written, because issuing national guidance alone does not ensure that safe and effective tapering programs are established. Furthermore, VHA did not specify how safety and effectiveness within a tapering program would be measured, nor did the agency specify a deadline for the required action as described in December 2014. According to federal internal control standards relating to the establishment and review of performance measures and indicators, government agencies should use appropriate information to adequately assess performance, including establishing milestones or numerical targets, as appropriate. Without clearly defined and measurable outcomes, VHA cannot fully assess its progress towards meeting this OSI goal.

VHA Has Not Implemented Certain CARA Requirements Related to Monitoring Veterans Prescribed Opioids

We also found that VHA has not implemented two CARA requirements intended to improve opioid safety for veterans. First, CARA requires that VHA’s Opioid Therapy Risk Report (OTRR) have the ability to determine whether a provider has prescribed opioids to a veteran without checking that veteran’s information in the OTRR. Available to providers through VHA’s electronic medical record system, OTRR is a clinical tool that provides information on any opioid and concurrent benzodiazepine prescriptions a veteran is receiving, the veteran’s current and prior health conditions, recent and upcoming appointments, and whether any opioid risk mitigation strategies have been employed (such as urine drug screening or PDMP query). However, we found that VHA Central Office cannot track the extent to which VHA providers use OTRR because this tool does not have this tracking capability. VHA officials said that adding tracking capabilities to OTRR is not a high priority for the agency due to limited resources and competing priorities. Instead, according to a draft memorandum, VHA Central Office is planning to address this CARA provision by requiring VHA providers to document the use of OTRR in a standardized way that VHA can monitor. However, as of March 2018, VHA has not established this requirement or outlined the process for monitoring providers’ use of OTRR. Without the ability to track the use of OTRR, VHA cannot sufficiently monitor whether providers are using the tool to help reduce the likelihood of opioid-related adverse events occurring among veterans receiving care through VHA.

CARA also requires that VHA modify its electronic medical record system so that any provider who accesses the record of a veteran will be notified whether that veteran is receiving opioid therapy and has a history of substance abuse disorder or prior instances of overdose; has a history of opioid abuse; or is at risk of developing an opioid use disorder. However, we found that VHA does not plan to modify its electronic medical record system to implement this capability. When asked about this provision in CARA, VHA officials said that VHA’s medical record currently has real- time alerts to inform providers about veterans’ existing opioid prescriptions and that any patient exposed to an opioid could be at risk of developing an opioid use disorder. Additionally, they said that an alert regarding current or past history of opioid use disorder could have an unintended consequence of discouraging veterans from reporting their medical history due to the stigma surrounding drug use disorders.

VHA Providers Do Not Always Adhere to Required Opioid Safety Risk Mitigation Strategies and Guideline Recommendations for Prescribing Opioids in a Safe Manner

VHA Providers at Selected Medical Facilities Do Not Consistently Follow Opioid Risk Mitigation Strategies

Our review of selected VHA medical facilities shows that providers do not always follow three key opioid risk mitigation strategies, two of which are required under VHA policy. Specifically, increasing the use of urine drug screening is an explicit goal of the OSI, and providers should generally ensure that an annual urine drug screening has been conducted. VHA policy requires providers to 1) query state PDMPs at least annually when prescribing opioids to determine if the veteran has obtained opioid medications or other controlled substances from a non-VA provider and 2) obtain written informed consent from patients about the risks of initiating long-term opioid therapy. These strategies are intended to help ensure that patients at VHA medical facilities are safely prescribed opioid medications. Overall, based on our review of 103 veterans at five selected facilities, we found that 75 percent of the veterans in our sample had an annual urine screening, 26 percent had their names queried in a PDMP, and 70 percent provided informed consent.

Provider Adherence to Three Veterans Health Administration (VHA) Opioid Risk Mitigation Strategies at Five Selected Medical Facilities, March 2016 through March 2017 Increasing the use of urine drug screening is an explicit goal of VHA’s Opioid Safety Initiative (OSI), and providers should generally ensure that an annual urine drug screening has been conducted. VHA policy requires providers to (1) query state prescription drug monitoring programs (PDMP) at least annually when prescribing opioids to determine if the veteran has obtained opioid medications or other controlled substances from a non-VA provider, and (2) obtain written informed consent from patients about the risks of initiating long-term opioid therapy. However, our review of medical records for a random nongeneralizable selection of 103 veterans subject to these risk mitigation strategies found that Of the 53 veterans who received long-term opioid therapy: 32 veterans received an annual urine drug screening, which allows providers to monitor the types of medications in a veteran’s system, including controlled and illicit substances; 13 veterans had their names queried annually in a state PDMP to see if they had received prescriptions for controlled substances, including opioids from non-VHA prescribers; and 41 veterans had provided informed consent indicating that they had been educated on the risks and benefits of opioid use.

Of the 25 veterans prescribed an opioid and benzodiazepine concurrently: 17 veterans received an annual urine drug screening; 8 veterans had an annual PDMP query; and 22 veterans had provided informed consent.

Of the 25 veterans with the highest risk of an adverse event, such as a suicide, overdose, fall, or accident, based on their Stratified Tool for Opioid Risk Mitigation (STORM) risk score: 24 veterans received an annual urine drug screening; 5 veterans had an annual PDMP query; and 11 veterans had provided informed consent.

We identified a number of factors that may have contributed to the inconsistent adherence to the three key opioid risk mitigation strategies at our selected VHA medical facilities. These factors may impede providers’ ability to consistently follow these strategies for all applicable patients at these facilities. To the extent that these factors are present across other facilities, VHA’s ability to ensure that all veterans are prescribed opioids in a safe and effective manner may be limited.

PDMP access issues. Officials at four of the five selected medical facilities faced PDMP access issues. Officials at two facilities told us that not all facility staff can access state PDMPs due to state laws and regulations that do not allow access to all types of providers, such as nurses and pharmacists. Officials at one of these selected facilities explained that nurse practitioners in that state cannot access the state’s PDMP, so they must rely on other providers to obtain information from the PDMP about their patients. In addition, in some states, only providers licensed in the state may access the state’s PDMP. Because providers at VHA facilities may not be licensed in the state where the VHA facility is located but licensed in another state, these providers may be unable to access the state’s PDMP. Officials at two selected facilities also described difficulties accessing PDMPs in neighboring states that are part of the catchment area for the facility and where the veteran may reside. The low rates of adherence we identified may also be attributed to the fact that VHA did not require providers to query the PDMP until October 2016, 7 months into our review of patients from March 2016 to March 2017.

CARA directed VA to ensure access by VHA providers to information on controlled substances prescribing through state PDMPs, including by seeking to enter into memoranda of understanding with states to allow shared access of such information between states and the VA. According to VHA officials, VHA Central Office has not taken steps to develop memoranda of understanding with states, nor has it developed any related guidance. Officials said this issue is likely being addressed by individual VISNs and medical facilities. In addition, VHA officials told us they have communicated with Members of Congress and the National Governors Association to address issues related to VHA provider access to the state PDMPs.

Lack of required staff to support providers. We also found that not all of the selected medical facilities and their respective VISNs had filled required staff positions that can help ensure provider adherence to opioid risk mitigation strategies—specifically, academic detailers and pain champions.

At the time of our review, not all facilities had access to VISN academic detailing services, which, according to VHA, can help ensure that providers follow opioid risk mitigation strategies. While VHA officials said that most VISNs across VHA had implemented an academic detailing program as required by VHA policy, two of the five VISNs for the selected facilities in our review had not. Nationally, as of March 2018, four VISNs had not implemented an academic detailing program. Additionally, 11 facilities across VHA had not received a visit from a detailer.

At the time of our review, four of five selected facilities did not have a Pain Champion as required by VHA policy beginning in March 2015. Pain champions are generally primary care providers knowledgeable about pain care who can serve as a resource for other primary care providers by promoting safe and effective pain care. According to VHA officials, pain champions play a critical role in opioid safety and can help providers remedy gaps in pain care management for individual patients, such as incomplete opioid risk mitigation strategies.

Lack of clinical opioid safety alerts. Another factor that may limit adherence to the opioid risk mitigation strategies is the fact that none of the selected facilities employ electronic reminders to help remind primary care nurses of strategies that have not been completed. Primary care nurses are typically responsible for ensuring adherence to these strategies, and VHA facilities often employ electronic alerts to notify providers when certain tasks need to be completed, such as regular screenings for depression and traumatic brain injury. Although VHA facilities are not required to develop these alerts, according to some primary care nurses we interviewed, it would be helpful to receive a reminder when a veteran is due for a PDMP query, urine drug screening, or has not given long-term opioid use informed consent. According to the nurses, such an alert could be issued through the electronic medical record system.

Limited facility monitoring. We found that facilities’ monitoring of provider adherence to the opioid risk mitigation strategies was limited across the five selected facilities in our review, which could hinder identification of non-adherence to these strategies. Specifically, while we found that all five medical facilities and VISNs in our review have an active pain management committee, facility officials told us that three of five facility committees do not conduct regular medical record reviews, which VHA encourages under its pain management directive to improve pain management. The directive states that facility pain management committees should monitor the pain management practices at their facility. For example, the pain management committee could monitor providers’ care plans for individual veterans, which are to be documented in the veterans’ medical records. These types of medical record reviews could help identify providers who are not adhering to VHA’s opioid safety requirements.

Some VHA Providers Do Not Consistently Follow Clinical Practice Guideline Recommendations Related to Opioid Safety

We also found that some VHA providers at selected facilities do not consistently follow selected clinical practice guideline recommendations related to opioid safety. Our findings are based on our review of a random selection of medical records for 103 veterans prescribed opioids between March 2016 and March 2017. These guidelines recommend, for example, that providers consider using non-pharmacological treatments, such as acupuncture and yoga, for chronic pain and prescribe naloxone, a potentially lifesaving drug, as warranted. The guidelines provide evidence-based recommendations designed to assist in provider decision-making; however, they are not VHA requirements and variations in practice will occur based on provider discretion and the needs of individual patients. Overall, we found that, 20 percent of veterans in our sample were prescribed a non-pharmacological therapy, 23 percent of the veterans were prescribed naloxone, 54 percent had appropriate maintenance follow-up visits with a provider while prescribed opioids, and 17 percent had appropriate follow-up visits with a provider after a change in their opioid prescription.

Provider Adherence to Selected Clinical Practice Guideline Recommendations for Management of Opioid Therapy for Chronic Pain at Five Selected Veterans Health Administration (VHA) Medical Facilities, March 2016 through March 2017 Clinical practice guidelines provide evidence-based recommendations designed to assist in provider decision-making; however, they are not VHA requirements and variations in practice will occur based on provider discretion and the needs of individual patients. Our review of medical records for a random, nongeneralizable selection of 103 veterans subject to the recommendations found that Of the 53 veterans who had been prescribed long-term opioids: 11 veterans were prescribed a non-pharmacological therapy, such as yoga, or cognitive behavioral therapy; 13 veterans were prescribed naloxone, which is a highly effective intervention for reversing an overdose; 29 veterans had a maintenance follow-up visit at least once every 30-180 days for the duration of the veteran’s opioid therapy; and 3 of 21 veterans who had a change in their opioid medication during the time of our review had a follow-up visit between 14 and 28 days following the change.

Of the 25 veterans prescribed a concurrent opioid and benzodiazepine: 6 veterans were prescribed a non-pharmacological therapy; 4 veterans were prescribed naloxone; 11 veterans had a maintenance follow-up visit; and 0 of 9 veterans who had a change in their opioid medication during the time of our review had a follow-up visit between 14 and 28 days following the medication change.

Of the 25 veterans with the highest risk of an adverse event, such as a suicide, overdose, fall, or opioid-induced respiratory depression, based on their Stratified Tool for Opioid Risk Mitigation (STORM) risk score: 4 veterans were prescribed a non-pharmacological therapy; 7 veterans were prescribed naloxone; 16 veterans had a maintenance follow-up visit; and 5 of 17 veterans who had a change in their opioid medication during the time of our review had a follow-up visit between 14 and 28 days following the medication change.

There are a variety of reasons that VHA providers may not always follow clinical practice guideline recommendations. For example, the availability of these non-pharmacological therapies may be limited, according to officials at all five selected VHA medical facilities. Officials at some facilities noted that the availability of these therapies can be particularly challenging for facilities in rural areas.

VHA officials explained that the biggest barrier to providing naloxone is educating providers, so that they consistently consider prescribing naloxone for their patients receiving opioid therapy. According to officials, an education course for providers on naloxone prescribing became available in December 2015, and naloxone education efforts are a key focus of academic detailing programs. According to VHA data, since fiscal year 2014, naloxone distribution has increased. Specifically, as of March 2018, the agency has dispensed almost 142,000 naloxone kits to veterans, an increase of about 58 percent since June 2017.

Conclusions

VHA is taking important steps under the OSI to help ensure that veterans receive safe care. For example, VHA has begun tracking and publicly reporting data on four key metrics related to opioid prescriptions, and these data show that opioid prescription rates have decreased since 2013. In addition, our review also found that VHA has made progress on most of its 2014 OSI goals. However, for two goals, VHA lacks documentation showing whether VISNs and medical facilities have completed required relevant actions, and in one case, VHA has not specified measurable outcomes, which makes it challenging to determine whether these goals have been accomplished. Without sufficient documentation and measurable outcomes, VHA cannot determine whether these OSI goals to help ensure safe and effective care for veterans prescribed opioids have been fully successful.

Our review also shows that VHA needs to do more to ensure that its providers are following three key opioid risk mitigation strategies when prescribing an opioid medication to a veteran: conducting an annual urine drug screening, querying a PDMP, and obtaining written informed consent from the veteran on the benefits and risks of using opioid medications.

VHA has several means at its disposal for improving adherence to these strategies—at a minimum it should ensure that each VISN has a fully staffed academic detailing program and that each facility has a designated primary care pain champion, as VHA policy requires. In addition to enforcing these requirements, VHA should direct its facilities to strengthen monitoring efforts to help ensure providers’ adhere to the opioid risk mitigation strategies. These efforts include regular reviews of veterans’ medical records and creating electronic alerts reminding providers when these risk mitigation strategies have not been completed. Academic detailers and pain champions would also help educate providers further about evidence-based clinical practice guideline recommendations, such as non-pharmacological alternatives to opioid therapy and prescribing naloxone. Without these efforts to improve adherence to key opioid risk mitigation strategies, VHA’s ability to ensure that all veterans are prescribed opioids in a safe and effective manner may be limited.

Recommendations for Executive Action

We are making the following five recommendations to VA:

The Undersecretary for Health should ensure that Central Office, VISNs, and medical facilities document the actions they take towards achieving OSI goals. (Recommendation 1)

The Undersecretary for Health should ensure that any OSI goals that have not been met have clearly defined, measurable outcomes, including milestones or numerical targets, as appropriate, and timeframes. (Recommendation 2)

The Undersecretary for Health should track the use of the OTRR (or any subsequent tool) by providers prior to initiating opioid therapy. (Recommendation 3)

The Undersecretary for Health should ensure that all VISNs have implemented an academic detailing program that supports all medical facilities in the VISN and that all VHA medical facilities have a designated primary care pain champion as required. (Recommendation 4)

The Undersecretary for Health should require VHA medical facilities to take steps to ensure provider adherence to opioid risk mitigation strategies, including querying PDMPs, obtaining written informed consent, and conducting urine drug screening. For example, these steps could include creating alerts in the electronic medical record system to remind primary care teams when these actions should be completed or strengthening facility monitoring of providers. (Recommendation 5)

Agency Comments

We provided a draft of this report to VA for comment. While VA was reviewing a draft of this report, it requested further specificity in recommendation two; as a result, we revised the recommendation to be clearer. In its written comments, which are reproduced in appendix II, VA concurred with our recommendations and provided technical comments, which we have incorporated as appropriate.

In its comments, VA agreed that clarifying ongoing priorities and plans and filling in gaps in implementation will help facilitate progress in its opioid safety efforts. VA stated that it will establish a workgroup to review all OSI goals and ensure that the goals have clearly defined measurable outcomes and timelines, and that documentation requirements are established. VA also informed us that in March 2018 it published a notice requiring VHA clinicians to conduct and document a data-based risk review using one of VHA’s clinical decision support tools for opioid management, such as STORM, prior to initiating opioid therapy. VA also stated that it will take actions to ensure that academic detailing programs are fully implemented and primary care pain champions are in place across the system. To improve its clinicians’ adherence to opioid risk mitigation strategies, VA stated that it will establish a workgroup to review and develop methods for increasing adherence. VA expects to complete all these actions by April 2019 or earlier.

We are sending copies of this report to the appropriate congressional committees, the Secretary of Veterans Affairs, the Undersecretary for Health, and other interested parties. In addition, the report is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-7114 or clowersa@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III.

Appendix I: Known Efforts and Data Related to the Veterans Health Administration’s (VHA) Opioid Safety Initiative (OSI) 2014 Goals, July 2013-December 2017

Description of known related efforts and data According to VHA training system data, 13 of 21 VISNs developed at least one education course addressing the use of urine drug screening from January 1, 2015 through April 29, 2017. Ten of the 13 VISNs developed at least one course by the deadline (December 31, 2014) as required. Further, 6 of the 13 VISNs had at least one course with 30 or fewer providers completing it. Because we found the VISN course assignment data unreliable, we could not determine the completion rates for these courses. However, we found that, in response to a 2015 White House memorandum that required all federal employee opioid prescribers to complete training on the appropriate prescribing of opioids (which included discussion of urine drug screening) by April 15, 2017, of 20,231 prescribers who were identified and assigned the course, 19,242 completed it, for a completion rate of about 95 percent, according to VHA data from January 1, 2015 through April 29, 2017.

Urine drug screening targets based on previous urine drug screening rates for all VHA facilities must be reached by 2nd quarter, fiscal year 2015 (March 31, 2015)

According to VHA data, 151 of 157 facilities met or exceeded their urine drug screening target by the deadline (March 31, 2015) as required. In addition, VHA OSI metric data also show that there has been a 47 percentage point increase nationally in the percentage of patients on long-term opioid therapy who received a urine drug screen from the 4th quarter of fiscal year 2013 to the 1st quarter of fiscal year 2018. The increase in the percentage of patients receiving a urine drug screening was driven more by a reduction in the total number of patients on long-term opioid therapy rather than an increase in the number of patients receiving the screening.

VHA Central Office lacks certifications from all VISNs that programs were established. Although officials at the five VISNs in our review told us they had supported training efforts on the use of PDMPs, only one VISN in our review provided documentation that it had established a program by the deadline (March 31, 2015) as required. However, in October 2016, VHA issued a directive requiring providers to query state PDMPs for patients prescribed opioids and also issued guidance on how PDMPs should be accessed and how these efforts should be documented in VA’s electronic health record system. In addition, according to VHA officials, querying the PDMP was added to the 2015 White House-required opioid safety training, as described earlier. According to VHA data, there has been a 22 percent increase in the querying of PDMPs by providers from 4th quarter, fiscal year 2016 to 3rd quarter, fiscal year 2017.

Description of known related efforts and data VHA Central Office lacks documentation from all VISNs regarding VISN-specific protocols and implementation plans. Only one of the five VISNs in our review provided documentation regarding a VISN-specific protocol relating to patients on opioids and benzodiazepines, which was developed in 2013. Four of the five VISNs did not provide documentation of a VISN-specific protocol or implementation plans. However, VHA officials told us that they addressed this goal by issuing national tapering guidance including a provider reference guide in 2014, an opioid taper decision tool in 2016, and the VA/DOD clinical practice guideline in 2017. VHA officials said that the issuance of this guidance made the VISN-required action irrelevant. In addition, VHA OSI metric data show that there has been a 6.6 percentage point decrease nationally in the percentage of patients dispensed an opioid and benzodiazepine from the fourth quarter of fiscal year 2013 to the first quarter of fiscal year 2018.

In 2016, VHA released its opioid risk stratification toolkit in the form of an opioid safety monitoring tool called the Stratification Tool for Opioid Risk Mitigation. In addition, VHA updated its pain management opioid safety education guide and quick reference guide for providers in July 2017.

VHA Central Office lacks documentation from all VISNs regarding VISN-specific protocols and implementation plans. Only one of the five VISNs in our review provided documentation regarding a VISN-specific protocol relating to patients on opioids and benzodiazepines, which was developed in 2013. Four of the five VISNs did not provide documentation of a VISN-specific protocol or implementation plans.

VHA-required action(s) Each VISN must certify that the treatment of all patients with a daily dose of greater than 200 morphine milligram equivalents has been reviewed by 2nd quarter, fiscal year 2015 (March 31, 2015)

Description of known related efforts and data VHA Central Office lacks certifications from all VISNs that reviews were conducted. Although officials at the five VISNs in our review told us they had completed these reviews, only one VISN provided us with documentation to conclude that its facilities completed their review. However, VHA OSI metric data show that there has been a 2.1 percentage point decrease nationally in the percentage of patients dispensed greater than or equal to 100 morphine milligram equivalents per day from the fourth quarter of fiscal year 2013 to the first quarter of fiscal year 2018.

Each facility must provide evidence that at least two evidence-based behavioral/psychological treatments or approved complementary or alternative modalities can be provided by 2nd quarter, fiscal year 2015 (March 31, 2015)

According to VHA 2nd quarter, fiscal year 2015 data, all VHA medical facilities located in the United States provided at least one psychosocial service and at least one complementary and integrative health service.

In February 2016, VHA began a pilot to implement a model of care known as the Collaborative Chronic Care Model into existing Behavioral Health Interdisciplinary Program teams at nine VHA medical facilities. According to a VHA document, the pilot will provide facilitation support to enhance existing Behavioral Health Interdisciplinary Program teams by incorporating evidence-based Collaborative Care Model elements, which can include a care manager to proactively monitor care and progress as well as other tools intended to improve communication between primary care and specialty care. In fiscal year 2017, efforts were expanded to 30 additional VHA medical facilities. According to one VHA official, the pilot is expected to be completed no earlier than August 2019.

VISNs are regional networks that manage the VHA medical facilities located in their area. In October 2015, VHA began to implement a realignment of its VISN boundaries which resulted in the number of its VISNs decreasing from 21 to 18. One VISN provided evidence of one VHA medical facility’s tapering recommendations for patients on opioids and benzodiazepines. Based on information we obtained from VHA relative to this goal, “psychosocial” services refer to “behavioral/psychological” treatments, and “integrated health” is a term that may be used to refer to “complementary and alternative” modalities. According to a VHA official, the VHA facility in Manila, the Philippines did not offer at least one psychosocial service and at least one integrative health service for this time period.

Appendix II: Comments from the Department of Veterans Affairs

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Marcia A. Mann, Assistant Director; Stella Chiang, Analyst-in-Charge; Emily Binek, Krister Friday, Diona Martyn, and Michael Rose made key contributions to this report. Also contributing were Zhi Boon and Emily Wilson.