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|Opioid Prescribing Safety|
AZ OPIOID TOOLKIT - Your resource for prescribing opioids under Arizona law.
HB 2075 & Electronic Prescribing of Controlled Substance (EPCS): Are you ready?
Read HB 2075 HERE.
HB 2075 (electronic prescribing; exceptions; deadlines),an emergency measure retroactive to December 31, 2018, passed early in the 2019 Legislative Session, delays the implementation date for electronic prescribing in all Arizona counties until January 1, 2020. The legislation eliminates the Arizona Board of Pharmacy's process for granting electronic prescribing waivers.The implementation dates of January 1, 2019 for the six largest counties and July 1, 2019 for all other counties, has been delayed until January 1, 2020 for all Arizona counties.
Beginning January 1, 2020, each prescription order for a schedule II-controlled substance that is an opioid must be transmitted electronically to the dispensing pharmacy in Arizona.
Other bill provisions:
When the Electronic Prescribing System is not Operational
During any period in which an electronic prescribing system is not operational or available in a timely manner, a medical practitioner may write or issue in an "emergency situation' a prescription order for a schedule II-controlled substance, that is an opioid. The medical practitioner must indicate on the written prescription order that the electronic prescribing system is not operational or available and must maintain a record of when the electronic prescribing system is not operational or available in a timely manner.
Federal Health Care Institutions
A medical practitioner may write or issue in an "emergency situation" a prescription order for a schedule II-controlled substance, that is an opioid, for a patient from a : Veterans Administration facility, a health facility on a military base, an Indian Health Services hospital or health service facility, or a tribal-owned clinic. The prescription order must indicate that the medical practitioner provided care for a patient in any one of the previous settings.
Background of the new law:
OPIOID ABUSE EPIDEMIC IN ARIZONA
The impact of opioid misuse is significant in our communities and the public health system. On June 1, 2017, the Arizona Department of Health Services (ADHS) released its latest data on opioid overdoses in Arizona showing the highest number of deaths in ten years. In 2016, 790 Arizonans died from opioid overdoses. This trend shows a startling increase of 74 percent over the past four years.
The 2016 opioid report shows over half of the 1,497 drug overdose deaths in that year were due to opioids as the primary cause of death. Opioids include heroin as well as prescription medication. The number of heroin deaths alone has tripled since 2012.
Research has found that approximately 3 out of 4 new heroin users report having abused prescription opioids prior to using heroin. Heroin is an opioid, and both drugs act on the same receptors in the brain to produce similar effects.
On January 25, 2018 the Arizona Legislature passed SB 1001, the Arizona Opioid Epidemic Act, which was signed into law by Governor Ducey on January 26, 2018. The Arizona Opioid Epidemic Act is an omnibus bill dedicated to curbing the opioid crisis. The legislation establishes requirements and certain limitations regarding the prescribing, administration and dispensing of schedule II opioids.
The bill has (6) major requirements that our Arizona Physicians (including residents) need to know:
STARTING APRIL 26, 2018
1. 5-day Limit on Initial Opioid Prescriptions
Limits the initial prescription for a patient for a schedule II controlled substance that is an opioid to no more than a five (5) day supply, except an initial prescription for a schedule II controlled substance that is an opioid following a surgical procedure is limited to no more than a fourteen (14) day supply.
An initial prescription is defined as follows:
“A prescription for a schedule II controlled substance that is an opioid that has not covered any portion of the past sixty days before the date the pharmacy dispenses the current prescription as evidenced by the controlled substances prescription monitoring program’s (CSPMP) central database tracking system.”
Exceptions to the initial prescription limitations apply if the patient:
2. 90 MME Dosage Limits
Prohibits healthcare providers from issuing a new prescription for a schedule II controlled substance that is an opioid that exceeds 90 MMEs per day.
The 90 MME limitation does not apply to:
A new prescription above 90 MME may be issued to a nonexempt patient after first consulting with a physician who is board-certificated in pain, or an opioid assistance and referral call service that is designated by DHS. If the opioid call service agrees with the higher dose, the health professional may issue a prescription for more than 90 MME. If the consulting physician is not available within 48 hours of the request the healthcare professional may prescribe and subsequently have the consultation; teleconference consultation is permissible. Physicians who are board-certified in pain may issue a prescription order above 90 MME without a consultation. If a patient is issued a new prescription above 90 MME per day, the prescriber must also prescribe Naloxone or other opioid antagonists.
Also, in response to the opioid epidemic the Arizona Department of Health Services, in conjunction with the Poison and Drug Information Centers in Arizona, has launched a 24/7 hotline which provides free, real-time consultations for clinicians with complex patients with pain and opioid use disorder.
3. Prohibits dispensing of opioids
Prohibits healthcare professionals from dispensing Schedule II controlled substances that are opioids and establishes violations as an act of unprofessional conduct. The law allows health care professionals to dispense an opioid that is an implantable device or that is for medication-assisted treatment for substance use disorders.
4. New CME Requirements – 3 hours of opioid education
Physicians who have a DEA registration number and are renewing their licenses are required to complete three (3) hours of opioid-related, substance use disorder-related or addiction-related continuing medical education as part of the 40 hours required.
Currently, a comprehensive course is available for free to all Arizona prescribers through the University of Arizona Office of Continuing Medical Education.
5. Medical Education – 3 hours of opioid education
Requires a student enrolled in a public or private medical program in this state and whose intended degree may make the student eligible for a United States Drug Enforcement Administration registration to take at least three hours of opioid-related clinical education.
6. Controlled Substances Prescription Monitor Program (CSPMP)
Eliminates the exemption that allows a health professional to not check the CSPMP if prescribing no more than a 5-day supply when the CSPMP has been reviewed in the last 30 days.
There are other provisions with upcoming implementation dates you should start preparing for now. Some of these will be impacted by other legislation currently in development.
CSMP (Controlled Substance Monitoring Program)
EFFECTIVE OCTOBER 16, 2017: All prescribers are required to obtain a patient utilization report from the Controlled Substances Prescription Monitoring Program (PMP) prior to prescribing an opioid analgesic or benzodiazepine controlled substance. It is the prescriber’s responsibility to understand the new law and the requirements.
ArMA and the Arizona Osteopathic Medical Association (AOMA) have created a compliance checklist resource: it can be downloaded here: CSPMP Compliance Checklist!
Review the final reporting rules HERE
Required reporters include the following:
Required reporters, including physicians, must use MEDSIS, for reporting the above listed health conditions. MEDSIS is the communicable disease reporting system, and it has been amended with new reporting fields.
HB 2075 mandates that beginning January 1, 2020, each prescription order for a schedule II-controlled substance that is an opioid must be transmitted electronically to the dispensing pharmacy in Arizona, regardless of what county it is issued in.
Here are immediate steps physicians can take to help our patient populations.