Mandatory Rule Changes for Doctors on Opioids

The Iowa Board of Medicine has adopted and amended its rules and regulations for opioid pain management are effective on November 27, 2019. The rules as amended can be reviewed at here.

While the Definition of “Chronic pain” currently has specific criteria; the Board’s new definition shifts the threshold from “… a few weeks …” to “… pain that typically lasts longer than three months or past the time of normal tissue healing. Chronic pain can be the result of an underlying medical disease or condition, injury, medical treatment, inflammation, or an unknown cause.”

The Board has also specifically added the definition of “Opioid,” which “… means any U.S. Food and Drug Administration (FDA)-approved product or active pharmaceutical ingredient classified as a controlled substance that produces an agonist effect on opioid receptors and is indicated or used for the treatment of pain.”

The new Board rules are specifically targeted to combat the opioid crisis and establish a new standard for disciplining cases in a which a physician, ” … prescribes opioids amounts exceeding what would be prescribed by a reasonably prudent physician in the state of Iowa acting in the same or similar circumstances.”

While this new standard is vague, the new rules provide some entirely new specific demands on pain treatment in Iowa.

The new Board requirements now explicitly require (1) a patient-doctor relationship and (2) the documentation of clearly diagnosed and unrelieved pain.

The Board also specifically references the CDC Guideline for Prescribing Opioids for Chronic Pain. This document is hyperlinked for your convenience here. With these guidelines being placed into the administrative rules, this will become the baseline the Board of Medicine will use for their decisions on the appropriate level of care.

The Board has substantially strengthened Iowa’s Prescription Monitoring Program (PMP) as well. While before it was left to the prescribing physician’s discretion to access the PMP, a physician will be required (with limited exceptions) to use the PMP prior to issuing an opioid.

The new rules also highlight discipline for violations of confidentiality provisions, specifically, the inappropriate accessing, disclosing or using information obtained from the PMP. The rule states that any such violation is considered a Class “D” felony. The Iowa Code Sections is attached here.

However, the largest change that will affect you on a daily basis will be that on January 1, 2020, all prescriptions (controlled and non-controlledsubstances) are mandated to be transmitted electronically as electronic prescriptions. Electronic prescriptions have been the norm for a lot of the larger clinics but will be a change for some of the smaller clinics. You will be required to transmit all your future prescriptions by electronic means.

It is important for you, as a practitioner, realize that these electronic systems are no longer tools, they are compulsory. Physicians, in the treatment of pain, must use the PMP, issue all prescriptions electronically and make sure your documentation is extensive, including the nature, duration, and assessment of the pain involved. This documentation must include all escalation in pain management treatments and any justification for why an opioid regiment is pursued.