Page 14 - Volume 70 Number 2
P. 14

WHAT THE NEW LAWS REQUIRE:
Some Good Things,
Some Not So Good
By Richard E. Burney, MD
There have been a number of stories and announce- ments of what the new laws regulating the prescrip- tion of Schedule II-V drugs require, but the changes are worth repeating. Some of them are reasonable and may be helpful. If nothing else, they mean well. Some of them, on the other hand, may well be unnecessarily burdensome and deter compassionate patient care. For much of the following I am indebted to Michigan State Medical Society for their informational bulletins. See https://www.msms.org/Resources/Quality-Patient-Safety/ Reversing-the-Opioid-Epidemic
Michigan Automated Prescription System (MAPS), Now PMP AWARxE
Registration with MAPS will be required for any physi- cian who wishes to prescribe a schedule II through V drug. Having been a registered MAPS user for several years, I have found that this is not a terrible burden. and have run MAPS reports once in while, specifically on patients who you are concerned may be abusing drugs are receiving prescriptions from multiple sources. The new MAPS system is quite responsive, unlike the old one. (Since it is operated by a private contractor, it also contains sales pitches.) The chief nuisance is that you have to change the password every 3 months, unless that has changed.
Enrollment in MAPS
All physicians who write any controlled substance prescriptions, which includes such things as Adderall for ADHD, will be required to enroll in the Michigan Automated Prescription System. Enrollment is a good thing. It takes 15 or 20 minutes to figure out how to do it and complete the enrollment form on line: https://michigan.pmpaware.net/login.
Bona Fide Prescriber-Patient Relationship
The legislature has taken it upon itself to define “bona fide prescriber-patient relationship” for purposes of prescribing controlled substances. In the past, they have also defined “bona fide doctor patient relationship” for the purposes of certifying medical marijuana use. I would have preferred they leave operational definitions like this to the Michigan Board of Medicine rather than codifying them in law, which is a lot harder to change in the future.
Prescribing controlled substances, interestingly, can be done by “telehealth.” This could be a significant benefit for tertiary care centers, whose patients may reside at a distance from care providers. At the same time, it could open a loophole because it means prescribing can be done by
anyone anywhere in the country who happens to have a Michigan license to practice. You can’t do that for marijuana.
Prescribers also have to create and maintain records of the patient’s condition, which can easily be done now using an EHR templated note.
Potential problems and unintended consequences that might leave patients in the lurch have been identified with this requirement, which has led to the introduction of a legislative modification to delay implementation for a year
Mandatory Checking of MAPS Prior to Writing More than 3 Days Supply
This idea was not evidence-based, but rather reflects a statement in a CDC guideline (see below) that for most patients 3 days is sufficient and patients rarely need more that a 7-day supply of an opioid for acute pain. It will surely affect prescribing practices and could be problematic. Other current recommendations for opioid prescribing actually allow for more than a 3-day supply, depending on what the prescription is for and what the reasonable anticipated patient needs are. After doing an outpatient surgical procedure, the most efficient thing to do if you don’t want to take the time to run a MAPS inquiry or can’t remember your password, will be never to write for more than 3 days of an opioid medication, if you write for one at all. (See separate article on current recommendations for post-op opioid prescribing.)
It may be possible to integrate MAPS inquiries into large system electronic health records, which would overcome the inconvenience of signing on to MAPS several times a day. This service would come at a price, more than likely, which would have to be negotiated between the health care system and the MAPS vendor.
If you regularly deal with patients who have chronic pain, or work in an Emergency Department seeing patients with acute injuries, or see patients who are post-op from major operations, you will need to set up some kind of system to pull these reports ahead of time. The vast majority of MAPS reports will be superfluous and will not alter prescribing in any way. They could well just become another meaningless administrative burden for the sake of meeting regulations, and will be ignored.
It is not clear that this regulation is even enforceable. How would anyone know? As far as I know, MAPS inquiries are not linked in any way to prescribing, even in electronic prescription writing systems. How much unnecessary documentation would be called for to prove that for every prescription written a MAPS report was requested?
14 Washtenaw County Medical Society BULLETIN APRIL / MAY / JUNE 2018














































































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