Update to Federal and State Controlled Substance Laws and - - PowerPoint PPT Presentation

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Update to Federal and State Controlled Substance Laws and - - PowerPoint PPT Presentation

Update to Federal and State Controlled Substance Laws and Guidelines Tennessee Radiological Society 2020 Annual Scientific Meeting February 22, 2020 Tyler Dougherty, PharmD Assistant Professor of Pharmacy Practice South College School of


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Update to Federal and State Controlled Substance Laws and Guidelines

Tennessee Radiological Society 2020 Annual Scientific Meeting February 22, 2020 Tyler Dougherty, PharmD Assistant Professor of Pharmacy Practice South College School of Pharmacy

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I have no financial relationships to disclose and I will not discuss off label use or investigational use in my presentation.

Disclosure Information

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  • Compare and contrast chronic pain guidelines and their

applications

  • Discuss the role of co-prescribing naloxone in high risk

patients

  • Review the Tennessee buprenorphine treatment

guidelines and challenges with medication-assisted treatment (MAT)

  • Examine new and potential federal and state legislation

affecting opioid prescribing

  • Utilize the Tennessee Controlled Substance Monitoring

Database in practice

Objectives

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PRESCRIBING OPIOIDS NALOXONE

MAT

LEGISLATION

CSMD

CURRENT LANDSCAPE

Outline

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Current Landscape

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  • 70,237 drug overdose deaths in 2017
  • 47,600 overdose deaths related to opioids
  • 191,146,822 opioid prescriptions dispensed by retail

pharmacies

  • >17,000 people die annually from prescription opioid
  • verdose (46/day)
  • Largely remained unchanged
  • Heroin overdose death rates have largely remained

unchanged

  • More than 28,000 deaths involving synthetic opioids in

2017

  • Almost a 50% relative change from 2016

National Landscape

Scholl L, Seth P, Kariisa M, et al. Drug and Opioid-Involved overdose Deaths – United States, 2013-2017. MMWR. 67 (51 & 52): 1419-1427. https://www.cdc.gov/mmwr/volumes/67/wr/pdfs/mm675152e1-H.pdf

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National Landscape

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1094 1166 1263 1451 1631 1776 1818

200 400 600 800 1000 1200 1400 1600 1800 2000

2012 2013 2014 2015 2016 2017 2018 Number of Deaths Year

TN Overdose Deaths

Tennessee Drug Overdose Dashboard. TN Department of Health. https://www.tn.gov/health/health-program-areas/pdo/pdo/data-dashboard.html

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  • 1,818 total overdose deaths
  • 1,304 deaths attributed to opioids
  • Fentanyl deaths increased 70%
  • 43% of individuals who died from a drug overdose had a

controlled substance dispensed within the last 60 days

  • Heroin deaths increased 20%
  • 44% of opioid-related overdose deaths included a

benzodiazepine

TN Landscape – 2018 Data

Controlled Substance Monitoring Database: 2019 Report to the 111th Tennessee General Assembly. March 1, 2019. https://www.tn.gov/content/dam/tn/health/healthprofboards/csmd/2019%20Comprehensive%20CSMD%20Annual%20Report.pdf

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  • From 2012-2018, number of MME dispensed has

decreased 43%

  • 2012-2018 number of opioid prescriptions for pain

have decreased by 30%

  • 2012-2018 number of patients receiving >120

MME/day has decreased 48%

  • First year on record for decrease in NAS cases
  • Stimulant prescribing continues to increase
  • 51% growth from 2010-2018

TN Landscape

Controlled Substance Monitoring Database: 2019 Report to the 111th Tennessee General Assembly. March 1, 2019. https://www.tn.gov/content/dam/tn/health/healthprofboards/csmd/2019%20Comprehensive%20CSMD%20Annual%20Report.pdf

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Controlled Substance Monitoring Database: 2019 Report to the 111th Tennessee General Assembly. March 1, 2019. https://www.tn.gov/content/dam/tn/health/healthprofboards/csmd/2019%20Comprehensive%20CSMD%20Annual%20Report.pdf

TN Landscape

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Miller AM, McDonald M (2019). Neonatal Abstinence Syndrome Surveillance Annual Report 2018. Tennessee Department of Health, Nashville,

  • TN. https://www.tn.gov/content/dam/tn/health/documents/nas/NAS%20Annual%20Report%202018%20FINAL.pdf

TN Landscape

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Controlled Substance Monitoring Database: 2019 Report to the 111th Tennessee General Assembly. March 1, 2019. https://www.tn.gov/content/dam/tn/health/healthprofboards/csmd/2019%20Comprehensive%20CSMD%20Annual%20Re port.pdf

TN Landscape

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PRESCRIBING OPIO IOIDS DS

Chronic Pain Guidelines

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  • Assess risk factors prior to initiating opioids
  • Previous treatments
  • Co-morbidities
  • History (overdose, SUD)
  • CSMD
  • Can use a therapeutic trial of opioids
  • Requires informed consent and treatment

agreement

  • Use the lowest effective dose
  • 50 MME/day
  • 90 MME/day

CDC Chronic Pain Guidelines

CDC Checklist: https://www.cdc.gov/drugoverdose/pdf/pdo_checklist-a.pdf

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  • Avoid benzodiazepines with opioid
  • Must use UDT at onset and at least annually
  • Check PDMP at onset and every three months
  • Follow up with patient:
  • Change of dose: 1-4 weeks
  • Stable dose: every 3 months
  • Acute pain: 3 days sufficient, 7 days rarely

CDC Chronic Pain Guidelines

CDC Checklist: https://www.cdc.gov/drugoverdose/pdf/pdo_checklist-a.pdf

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Limitations to CDC Guidelines

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  • Inflexible application of recommended ceiling

doses/durations as hard limits

  • Abrupt opioid taper or cessation
  • Limited coverage and access to multi-modal,

comprehensive care

  • OUD diagnosis difficulty and access barriers
  • Payors applying dosage limits

Kurt Kroenke, Daniel P Alford, Charles Argoff, Bernard Canlas, Edward Covington, Joseph W Frank, Karl J Haake, Steven Hanling, W Michael Hooten, Stefan G Kertesz, Richard L Kravitz, Erin E Krebs, Steven P Stanos, Mark Sullivan, Challenges with Implementing the Centers for Disease Control and Prevention Opioid Guideline: A Consensus Panel Report, Pain Medicine, Volume 20, Issue 4, April 2019, Pages 724–735, https://doi.org/10.1093/pm/pny307

Limitations to CDC Guidelines

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Petrosky E, Harpaz R, Fowler KA, et al. Chronic Pain Among Suicide Decedents, 2003 to 2014: Findings From the National Violent Death Reporting

  • System. Ann Intern Med. [Epub ahead of print 11 September 2018]169:448–455. doi: 10.7326/M18-0830
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Individualized, Integrative Treatment

U.S. Department of Health and Human Services (2019, May). Pain Management Best Practices Inter-Agency Task Force Report: Updates, Gaps, Inconsistencies, and Recommendations. Retrieved from U. S. Department of Health and Human Services website: https://www.hhs.gov/ash/advisory-committees/pain/reports/index.html

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Tapering: Benefits vs Risk

Dowell D, Compton WM, Giroir BP. Patient-Centered Reduction or Discontinuation of Long-term Opioid Analgesics: The HHS Guide for

  • Clinicians. JAMA. Published online October 10, 2019. doi:10.1001/jama.2019.16409.
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  • Can use a therapeutic trial of opioids
  • Requires informed consent and treatment

agreement

  • Use the lowest effective dose, immediate release

products

  • Discuss and document the 5 A’s (analgesia,

activities of daily living, adverse side effects, aberrant drug-taking behaviors and affects) at each visit

TN Chronic Pain Guidelines

Tennessee Chronic Pain Guidelines. https://www.tn.gov/content/dam/tn/health/healthprofboards/pain-management-clinic/ChronicPainGuidelines.pdf

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TCA §63-1-164

“Informed consent”… at a minimum: (i) Adequate information to allow the patient or the patient's legal representative to understand: (a) The risks, effects, and characteristics

  • f opioids, including the risks of physical

dependency and addiction, misuse, and diversion; (b) What to expect when taking an

  • pioid and how opioids should be used;

and (c) Reasonable alternatives to opioids for treating or managing the patient's condition or symptoms and the benefits and risks of the alternative treatments; A healthcare practitioner may treat a patient with more than a three-day supply of an

  • pioid if the healthcare practitioner treats the

patient with no more than one (1) prescription for an opioid per encounter and:(i) Personally conducts a thorough evaluation of the patient; (ii) Documents consideration of non-opioid and non-pharmacologic pain management strategies and why the strategies failed or were not attempted; (iii) Includes the ICD-10 code for the primary disease in the patient's chart, and on the prescription when a prescription is issued; and (iv) Obtains informed consent and documents the reason for treating with an opioid in the chart.

Acts 2018, ch. 1039, § 6; 2019, ch. 117, § 1; 2019, ch. 124, §§ 7-13.

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Informed Consent

Tennessee Chronic Pain Guidelines. https://www.tn.gov/content/dam/tn/health/healthprofboards/pain-management-clinic/ChronicPainGuidelines.pdf

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  • Primary Care Providers are encouraged to treat

patients requiring <120 MME/day

  • If patient requires >120 MME/day, must consult

with pain medicine specialist

  • If patient requires >120 MME/day for more than 6

months, must consult with a pain medicine specialist annually

TN Chronic Pain Guidelines

Tennessee Chronic Pain Guidelines. https://www.tn.gov/content/dam/tn/health/healthprofboards/pain-management-clinic/ChronicPainGuidelines.pdf

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  • Assess risk for abuse
  • ORT
  • SOAPP-R
  • Establish treatment goals
  • 3 item PEG Assessment Scale
  • Avoid benzodiazepines with opioid
  • Must use UDT at onset and at least twice yearly
  • Check CSMD at least twice yearly per law
  • Cannot use telemedicine

TN Chronic Pain Guidelines

Tennessee Chronic Pain Guidelines. https://www.tn.gov/content/dam/tn/health/healthprofboards/pain-management-clinic/ChronicPainGuidelines.pdf

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  • Pain present for <90 days
  • Can be spontaneous, surgical, or injury-related
  • Use multi-modal care:
  • Nonpharmacologic therapies
  • NSAIDs for 2-4 weeks
  • Education
  • If pain persists, can try three days or less of opioids

(tramadol, if not contraindicated)

  • Avoid extended-release formulations in acute setting
  • Evaluate for OUD and check CSMD

TN Chronic Pain Guidelines – Acute Pain

Tennessee Chronic Pain Guidelines. https://www.tn.gov/content/dam/tn/health/healthprofboards/pain-management-clinic/ChronicPainGuidelines.pdf

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  • Walmart: 7 day supply with up to 50 MME/day

limit for opioids for acute pain

  • Requiring e-prescribing for opioids in 2020
  • CVS/Caremark: 7 day supply with up to 90

MME/day limit for opioid prescriptions for acute pain

  • PA required for: day supply increase, MME increase, or ER

therapy

https://www.caremark.com/portal/asset/Opioid_Reference_Guide.pdf https://corporate.walmart.com/newsroom/2018/05/07/walmart-introduces-additional-measures-to-help-curb-opioid-abuse-and-misuse

Discrepancies Across Corporations

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  • Express Scripts: “Initial fill days’ supply rule for adults

initiating opioid therapy are limited to a 7-days’ supply for members’ first 4 fills, requiring a prior authorization to exceed 28-days’ supply in a 60-day period”

  • TennCare: “up to 15 days in a 180-day period at a

maximum dosage of 60 MME per day. After the first- fill prescription (less than or equal to 5 days), a member can receive up to an additional 10 days of

  • pioid treatment with prior authorization.”

https://lab.express-scripts.com/lab/insights/drug-safety-and-abuse/our-focus-opioid-recovery-and-abuse-prevention https://oig.hhs.gov/oas/reports/region4/41800124_Factsheet.pdf

Discrepancies Across Corporations

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  • “Red Flags”
  • Distance between doctor, pharmacy, and residence
  • Multiple pharmacies being used
  • “Cocktails”
  • Pre-printed/stamped pads
  • OBRA’ 90 Requirements
  • Duplicate therapies
  • Drug-disease contraindications
  • Counseling requirements
  • Insurance

Why does the Pharmacist call?

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“A prescription for a controlled substance to be effective must be issued for a legitimate medical purpose by an individual practitioner acting in the usual course of his professional

  • practice. The responsibility for the proper prescribing and

dispensing of controlled substances is upon the prescribing practitioner, but a corresponding responsibility rests with the pharmacist who fills the prescription. An order purporting to be a prescription issued not in the usual course of professional treatment or in legitimate and authorized research is not a prescription within the meaning and intent of Section 309 of the Act (21 U.S.C. §829) and the person knowingly filling such a purported prescription, as well as the person issuing it, shall be subject to the penalties provided for violations of the provisions of law relating to controlled substances (21 C.F.R. §1306.04(a)).”

Corresponding Responsibility Doctrine

Food and Drugs, 21 C.F.R. § 1306.04. https://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_04.htm

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NALOXONE

Co-Prescribing Naloxone

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Davis C. Legal interventions to reduce overdose mortality: naloxone access and overdose good Samaritan laws. The Network for Public Health Law. December 2018. https://www.networkforphl.org/_asset/qz5pvn/legal-interventions-to-reduce-overdose.pdf

Current State Naloxone Access

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Abouk R, Pacula RL, Powell D. Association Between State Laws Facilitating Pharmacy Distribution of Naloxone and Risk of Fatal Overdose. JAMA Intern Med. 2019; 179: 805-11.

  • States have various levels of naloxone access laws
  • Naloxone access has implications for fatal and non-

fatal opioid overdoses

Impact of NALs on Fatal Opioid Overdose Type of NAL Δ Fatal OD Rate 95% CI P-Value Direct Authority*

  • 0.387
  • 0.119 to -0.656

0.007 Indirect Authority 0.121

  • 0.014 to 0.257

0.09 Weak NAL 0.094

  • 0.040 to 0.227

0.17

*Opioid related ER visits increased 15% relative other states

Does Which State You Live in Matter?

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  • Vermont mandated when opioids prescribed >90

MEE/day OR with a concomitant benzodiazepine

  • Virginia mandated when opioids prescribed >120

MME/day or concomitant benzodiazepine

  • Tennessee currently has a statewide pharmacy

practice agreement

  • Naloxone can be dispensed to patients at risk of
  • verdose, to a family member or friend
  • Pharmacist is required to complete training course
  • Good Samaritan Law

Vermont Department of Health. Rule governing the prescribing of opioids for pain. http://www.healthvermont.gov/sites/default/files/documents/pdf/REG_ opioids-prescribing-for-pain.pdf. Published March 2019. Accessed April 28, 2019 Virginia Department of Health Professions, Board of Medicine. Board of Medicine regulations on opioid prescribing and buprenorphine. https://www.dhp.virginia.gov/medicine/newsletters/ OpioidPrescribingBuprenorphine03142017.pdf. Published 2017. Accessed April28, 2019.

Co-Prescribing Naloxone

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Consider in patients who:

  • >50 MME opioid dose with:
  • Co-morbidities making the patient more

susceptible to overdose

  • Concomitant benzodiazepine use
  • History of SUD
  • Polypharmacy
  • Good Samaritan or family member

Co-Prescribing Naloxone

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MAT

Medication Assisted Treatment

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  • Enacted in 2000 with intent of allowing addicts to be

treated for addiction in office-based settings (outside of OTPs)

  • Only permitted drugs are buprenorphine SL and

buprenorphine-naloxone tablets/films

  • Treatment must be by a “qualifying physician”
  • Qualifying physician may not treat more than 100

patients and must obtain special DEA number

  • CARA 2016 increased the number of patients
  • Special DEA Identification number (DATA 2000 Waiver

ID or “X” number)

Drug Addiction Treatment Act (DATA)

DEA Requirements for DATA Waived Physicians. https://www.deadiversion.usdoj.gov/pubs/docs/dwp_buprenorphine.htm

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37051 43903 45525 48035 50741

10000 20000 30000 40000 50000 60000

2014 2015 2016 2017 2018 Number of Patients Year

Patients Receiving Buprenorphine in TN

Tennessee Drug Overdose Dashboard. TN Department of Health. https://www.tn.gov/health/health-program-areas/pdo/pdo/data-dashboard.html

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  • Buprenorphine products may only be prescribed for

a use recognized by the FDA

  • Buprenorphine without naloxone shall only be

prescribed for patients who are:

  • Pregnant
  • Nursing*
  • Documented allergy to naloxone (< 5%)
  • Licensed physicians are the only healthcare

provider authorized to prescribe for MAT

TN Buprenorphine Guidelines

Tennessee Nonresidential Buprenorphine Treatment Guidelines. TN Department of Mental Health and Substance Abuse Services. 2018. https://www.tn.gov/content/dam/tn/health/documents/2018%20Buprenorphine%20Tx%20Guidelines.PDF

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Name Dosage Form Strength (mg) Manufacturer Zubsolv SL Tablet 0.7/0.18, 1.4/0.36, 2.9/0.71, 5.7/1.4, 8.6/2.1, 11.4/2.9 mg Orexo Bunavail (Buprenorphine/Naloxone Buccal Film 2.1/0.3, 4.2/0.7, 6.3/1.0 mg BioDelivery Sciences International Suboxone (Buprenorphine/Naloxone SL Film 2.0/0.5, 4.0/1.0, 8.0/2.0, 12.0/3.0 mg Indivior, Sandoz, Mylan,

  • Dr. Reddy’s

Suboxone (Buprenorphine/Naloxone) SL Tablet 2.0/0.5, 8.0/2.0 mg Actavis, Amneal, Ethypharm, TEVA Subutex (Buprenorphine/Naloxone) SL Tablet 2, 8 mg Actavis, Barr, Mylan, Sun, Rhodes Sublocade SQ Injection (monthly) 100 mg/0.5ml, 300 mg/1.5ml Indivior Probuphine Implant (6 months) 74.2 mg (4 implants) Braeburn

Buprenorphine Approved for OUD

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  • Insurance coverage
  • SUPPORT ACT
  • Accessible providers
  • 83,000 MDs nation wide with DATA waiver
  • 1,900 MDs in TN with DATA waiver
  • Accessible pharmacies
  • Choosing to stock MAT
  • Buprenorphine without rx?*
  • Continuity of care
  • ER discharge
  • Confidentiality: HHS 42 CFR Part 2
  • Diversion: brand street value

*Roy PJ, Stein MD. Offering Emergency Buprenorphine Without a Prescription. JAMA. 322(6): 501-502. 13 August 2019.

Challenges with MAT

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LEGISLATION

Federal and State Legislation

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SUPPORT ACT

Title/Section Regulation

Title I – Medicaid Provisions to Address Opioid Crisis

State Medicaid programs establish DUR requirements for at-risk beneficiaries

Title II – Medicare Provisions to Address Opioid Crisis

Initial examination for new Medicare enrollees must include an OUD screening and prescription history review

Title VI – Medicare Opioid Safety Education Act

CMS must provide Medicare beneficiaries with education resources about opioid use and pain management, and covered nonopioid treatments

Title VI – Opioid Addiction Action Plan

CMS must develop an action plan on changes to Medicare/Medicaid programs to enhance treatment/prevention OUD and coverage of MAT

Title VI – Combatting Opioid Abuse for Care in Hospitals

CMS must publish guidance for hospitals on pain management and SUD. Recommend quality measures for OUD, reduction in opioid use in surgical setting, and pain-management strategies

The SUPPORT for Patients and Communities Act (H.R. 6). American Society of Addiction Medicine. https://www.asam.org/advocacy/the-support-for-patients-and-communities-act-(h.r.-6)

SUPPORT Act

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  • Encourage increased training on addiction/pain in

medical school and residency

  • New DATA 2000 waiver pathway for recent medical

school graduates who have completed DATA 2000 waiver training elements

  • Established loan repayment program for SUD

providers in high-need areas

  • Board-certified physicians in addiction medicine or

addiction psychiatry can immediately treat up to 100 patients (in stead of only 30)

Teach It

The SUPPORT for Patients and Communities Act (H.R. 6). American Society of Addiction Medicine. https://www.asam.org/advocacy/the-support-for-patients-and-communities-act-(h.r.-6)

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  • Authorizes $10M grant for hospitals to develop

protocols on discharging patients who presented with opioid overdose

  • Protocols should include:
  • Provision of an overdose medication at discharge
  • Connection with peer-support specialists
  • Referral to treatment and other services that best fit the

needs of the patient

Standardize It

The SUPPORT for Patients and Communities Act (H.R. 6). American Society of Addiction Medicine. https://www.asam.org/advocacy/the-support-for-patients-and-communities-act-(h.r.-6)

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  • Creates an outpatient OUD treatment demo in

Medicare

  • Increases reimbursement and accountability metrics
  • Focuses on care coordination using bio-psycho-social model
  • Medicare will begin covering OTP’s (01/01/20)
  • Bundles payments for holistic services and methadone

coverage

  • Starting October 2020, Medicaid must cover OUD

treatment medication

  • Starting January 1, 2021, C-II-V controlled substances

must be e-prescribed for Medicare patients

Cover It

The SUPPORT for Patients and Communities Act (H.R. 6). American Society of Addiction Medicine. https://www.asam.org/advocacy/the-support-for-patients-and-communities-act-(h.r.-6)

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  • Enacted in 1975 to address concerns about patient

information used in non-treatment settings

  • Part 2 programs are federally assisted: methadone and

buprenorphine OTP’s

  • Part 2 prohibits disclosure of patient records from

federally assisted programs that could identify the patient as having or had SUD

  • Patient can consent to release of info
  • Consent must include name of patient, name of entity

disclosing and receiving info, amount/kind of info

  • The Protecting Jessica Grubb’s Legacy Act

Disclosure of Substance Use Disorder Patient Records: How do I exchange part 2 data? The Office of the National Coordinator for Health Information Technology and

  • SAMHSA. https://www.samhsa.gov/sites/default/files/how-do-i-exchange-part2.pdf

42 CFR Part 2 – Protecting Jessica Grubb’s Legacy Act. http://opiodcrisisstg.wpengine.com/wp-content/uploads/2017/09/42-CFR-Part-2-One-Pager.pdf

HHS 42 CFR Part 2: Confidentiality

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  • SAMSHA is proposing revision to help facilitate better

coordination of care for SUD

  • Non-OTP providers will be able to query a central registry

to determine if patient is receiving treatment

  • OTP’s will be able to enroll in state PDMP and report to

PDMP C II-V that are prescribed or dispensed

  • Continue to prohibit law enforcement use of SUD records

in prosecution

HHS 42 CFR Part 2 Proposed Rule Fact Sheet. U.S. Department of Health and Human Services. 22 August 2019: https://www.hhs.gov/about/news/2019/08/22/hhs-42-cfr- part-2-proposed-rule-fact-sheet.html

HHS 42 CFR Part 2: Proposed Rule Change

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  • Allows for partial filling of C-II’s
  • Requested by the patient or practitioner
  • Total quantity dispensed in all partial fills cannot exceed

total quantity prescribed

  • Once a partial fill occurs, the remaining portion

may be filled within 30 days of the date on the Rx

  • If not, the prescriber should be notified
  • No further quantity can be dispensed after 30 days

without a new Rx

CARA 2016: Partial Fills

Comprehensive Addiction and Recovery Act 2016. 21 USC 829; 21 CFR 1306.13

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SLIDE 58

According to TNTogether legislation, what is missing on this prescription?

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Public Chapter 124 Amended: effective 4/9/2019

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MME Conversion

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  • PC 978 established a task force to define minimum

disciplinary action by TN licensing boards for prescribers who treat patients with opioids

  • If the licensing board/agency finds “that the

healthcare practitioner engaged in a significant deviation or pattern of deviation from sound medical judgement”, then:

  • Minimum disciplinary action must be imposed on the

practitioner

  • The minimum disciplinary action is binding on each

board/agency

Minimum Disciplinary Action: Opioid Prescribing

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SLIDE 67

The minimum discipline that the board or committee assesses shall include the following: a) Reprimand b) Successful completion of a board/committee approved intensive CE course on opioid c) Restriction against prescribing opioids for at least six months, and until completion of CE d) One or more Type A civil penalties e) Must notify all collaborative practitioners (PA, NP, etc) f) Restricted from collaborating with NP’s or PA’s during restriction

0880-02-.25. General Rules and Regulations Governing the Practice of Medicine. Minimum Discipline for Opioid Prescribing. https://publications.tnsosfiles.com/rules_filings/05-17-19.pdf

What is Minimum Discipline?

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SLIDE 68

Minimum discipline the board assesses shall include the following: a. Probation

  • b. Successful completion of practice monitoring

program including: quarterly reports of non-opioid prescribing practices, medical record keeping, pain management, opioid practices, additional CE c. Restriction against opioid prescribing for 2x the amount that was assessed originally (not less than 1 year)

  • d. One or more Type A civil penalties

e. Notification to collaborating providers

What about Repeat Offenders?

0880-02-.25. General Rules and Regulations Governing the Practice of Medicine. Minimum Discipline for Opioid Prescribing. https://publications.tnsosfiles.com/rules_filings/05-17-19.pdf

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TN CSMD Requirements

CSMD

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  • Must check CSMD before prescribing opioid or

benzodiazepine as a new episode of treatment

  • Do not have to check when prescribing 3 days or less
  • Must check every 6 months when controlled

substance remains apart of treatment plan

  • Best practice is to check regularly with each

prescription

  • Can authorize up to two delegates (“extenders”) to

check for you

  • Include access to your collaborating practitioners

Controlled Substance Monitoring Database (CSMD) and Prescription Safety Act: Frequently Asked Questions. https://www.tn.gov/health/health-program-areas/health- professional-boards/csmd-board/csmd-board/faq.html

Tennessee CSMD

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SLIDE 71

Controlled Substance Monitoring Database: 2019 Report to the 111th Tennessee General Assembly. March 1, 2019. https://www.tn.gov/content/dam/tn/health/healthprofboards/csmd/2019%20Comprehensive%20CSMD%20Annual%20Re port.pdf

Tennessee CSMD

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Practitioner Self Lookup

Slide courtesy of Dr. Todd Bess, Tennessee Controlled Substance Monitoring Database.

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Practitioner Self Lookup with Option for APRN/PA

Slide courtesy of Dr. Todd Bess, Tennessee Controlled Substance Monitoring Database.

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Practitioner vs. Peer Report

Slide courtesy of Dr. Todd Bess, Tennessee Controlled Substance Monitoring Database.

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Multi-State Lookup

Slide courtesy of Dr. Todd Bess, Tennessee Controlled Substance Monitoring Database.

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  • Number of overdose deaths continue to rise, yet the

number of opioid prescriptions are decreasing

  • Co-prescribing naloxone should be prescribed for high-

risk patients

  • Access to MAT is a problem but the SUPPORT Act will

help

  • Clean up of TN Together created functional changes

aligning state and federal law, while also attempting to balance safety and access

  • CSMD has clinical utility for patient management but

also for comparing own prescribing history

Summary