The Ohio Academy of Family Physicians has submitted comments on new State Medical Board of Ohio (SMBO) rules that implement Governor Kasich’s restrictions on prescribing opiates for acute pain.
In short, the SMBO has amended two existing rules and a proposed new rule that will limit initial opioid analgesic prescriptions for acute pain to five days for minors and seven days for adults. The rules also include a 30 morphine equivalency dosing (MED) average daily dose limit.
The OAFP’s comments focus on the following points:
- Requiring the ICD-10-CM medical diagnosis code on the prescription, including the description of the code, the primary disease or condition that the controlled substance is being used to treat, violates patient confidentiality.
- Under rules proposed, the diagnosis or procedure code for every controlled substance script will be entered into OARRS by the pharmacist. For what purpose is this confidential information being collected? How will this information be used?
- Electronic medical record systems do not readily allow diagnosis codes and duration of treatment information to be printed on the script. This is a complicated and expensive requirement to implement.
- Rules being implemented are much more stringent than the carefully constructed acute pain prescribing guidelines agreed upon by key stakeholder groups in early 2016. With the changes now proposed, prescribers can prescribe opiates in excess of no more than seven days for adults and five days for minors unless the reason is documented in the patient chart. The acute pain prescribing guidelines called for re-assessment at 14 days if pain had not subsided.
- There is no clinical judgment allowance for the total MED. The total MED of a prescription for acute pain cannot exceed an average of 30 MED per day.
- The Centers for Disease Control and Prevention’s (CDC) Guidelines for Prescribing Opioids for Chronic Pain released in March 2016 are claimed as the justification for these acute pain prescribing restrictions. The American Academy of Family Physicians found the CDC guidelines to be based on a review of contextual evidence using inconsistent inclusion and exclusion criteria for different pain management therapies. Because of these inconsistencies in methodology, and because strong recommendations were made on the basis of low-quality or insufficient evidence, the AAFP did not endorse the CDC guidelines.
Read the OAFP’s comment letter.
The deadline to submit comments is Friday, April 28, and the OAFP encourages members to send their own comments to the SMBO before the Friday deadline.