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Opioid Prescribing Rules and Guidelines

Opioid Prescribing Rules and Guidelines

An overview of rules governing prescribing practices for physicians and physician assistants in Washington state.

Opioid-Related Prescribing Rules in Washington

Comprehensive rules, required by House Bill 1427 (2017) and Senate Bill 5380 (2019) regulate opioid prescribing in our state. The boards and commissions that regulate prescribers of opioids each created separate rules. While the rules are largely aligned, there are minor but important differences across professions.

Key provisions for prescribing physicians and PAs

  • A seven-day pill limit for acute prescriptions and 14 days for acute operative pain, with an exemption to these limits when clinical judgment is documented in the medical record (as per HB 1427).
  • A specific care plan and documentation requirements for each phase of pain.
  • Mandated registration and targeted checks of the prescription drug monitoring program.
  • Required continuing medical education on opioid prescribing. The WSMA offers on-demand training to meet this requirement: Opioid Prescribing Regulations Post-COVID-19 Public Health Emergency (WSMA members only—sign-in required).
  • Notification to the patient of the risks of prescription opioids, including the risk of dependency and overdose, pain management alternatives to opioids when clinically appropriate, evidence-based alternatives, and notification that they have the right to refuse an opioid prescription for any reason (as per SB 5380).
    • To help you successfully incorporate this requirement into your workflow, the WSMA has updated its Epic-compatible pain management rule requirements checklist, available below.

Preparing to prescribe opioids

  1. Complete the one-hour, mandatory CME on opioid prescribing best practices.
  2. Register for the state's prescription monitoring program at the Washington State Department of Health.
  3. Read the prescribing rules relevant to your profession to understand rules around prescribing, CME, treatment planning, PMP checks, diagnosis, and ICD documentation. See this Department of Health chart for quick reference and see the information directly below.
  4. Build increased documentation and other new requirements into your workflow. The WSMA offers a WSMA Pain Management Rule Requirements Checklist to help. Learn more about Bamboo Health's PMP Gateway integration option below.

Before prescribing an opioid, you must:

  1. Perform and document patient evaluation.
  2. Create and/or document treatment plan.
  3. Provide the patient with information on the risks of opioids, their safe and secure storage and disposal, and the patient's right to refuse the prescription-the Department of Health offers patient handouts meeting this requirement.
  4. Consider (and in some cases, document) the use of alternative modalities for pain treatment when clinically appropriate.

Prescribing board and commission rules

There are instances where prescribing rules vary based on profession. For example, with treatment plans, MDs are not required to document them in the medical record, but DOs are. Additionally, MDs are required to check the PMP at targeted intervals, but DOs are required to conduct checks prior to the issuance of any prescription of an opioid or a benzodiazepine. Review this Department of Health summary of differences based on profession and consult the respective board and commission rules in full to understand the set of rules applicable to your profession:

Other Prescribing Rules in Washington

Updated June 2023

Schedule II oral prescriptions

The Pharmacy Quality Assurance Commission filed an emergency rule regarding Schedule II Oral Prescriptions that aligned state regulatory practice with the ongoing federal Drug Enforcement Administration's guidance on Schedule II prescribing standards during the COVID-19 pandemic. The duration of time a practitioner had to deliver a signed prescription of a Schedule II substance to the pharmacy increased from seven days to 15 days when a prescription is dispensed in an emergency. It also defined what a "signed prescription" meant and allowed for a practitioner to accomplish this requirement through paper, electronic transmission, facsimile, photograph, or scanned copy.

This emergency rule expired in June 2023. Upon expiration, the commission elected to adopt this guidance document addressing the guidelines instead of refiling the emergency rule. This guidance document will remain in effect until either the DEA's guidance is withdrawn, or the commission withdraws this guidance document at a future meeting.

Federal Prescribing Updates

Updated June 2023

DATA 2000 (X) waiver removed

In December 2022, the Substance Abuse and Mental Health Services Administration and the Drug Enforcement Agency eliminated the requirement for physicians and other prescribers to obtain a DATA 2000 (X) waiver to prescribe buprenorphine-containing medication products for the treatment of opioid use disorder. SAMHSA additionally dropped the limit on the number of patients to whom physicians may prescribe buprenorphine. The removal of these barriers to treatment represents a significant victory in the battle to reduce opioid addiction and overdose, one in which the WSMA and a coalition of Washington stakeholders played a critical role. Learn more on our Medications for Opioid Use Disorder page, where you'll also find resources to get started prescribing these life-saving medications.

New DEA registration requirement

The Consolidated Appropriations Act of 2023 requires a new training for physicians, physician assistants, and health care professionals who need DEA registration as a condition of employment or to prescribe controlled substances in Schedule II-V.

Starting in June 2023, upon registration with the DEA or renewal of a DEA number, physicians will be required to complete eight hours of training on the treatment and management of opioid use disorder or substance use disorder. The DEA and the SAMHSA released guidance around this new requirement.

The WSMA, with the Washington Society of Addiction Medicine, Women and Addiction Group, and CHOICES Education Group, hosted an education series in June to help physicians and physician assistants meet this new requirement. Access the recordings and materials on our Compassionate Addiction Medicine page.

CMS releases pain management codes for Medicare physicians

The Centers for Medicare and Medicaid Services rolled out new codes for bundled care effective Jan. 1, 2023. These codes describe a composite of services that pain-treating physicians provide to a patient every month. Rather than billing a la carte for these services, health care professionals can now report the bundled code monthly as a simpler way to collect for the care provided.

G3002 includes assessment, diagnosis, and monitoring of the patient's pain, including working with other clinicians to manage treatment. Note that this code can only be applied to the first 30 minutes of chronic pain management care.

For health care professionals who spend more than 30 minutes with their patient, use the new add-on code, G3003.

Learn more by reviewing the 2023 Medicare Physician Fee Schedule Final Rule released in November 2022.

WSMA Prescribing Resources

Education to meet state and federal prescribing requirements

Compassionate Addiction Medicine education series
The WSMA, with the Washington Society of Addiction Medicine, Women in Addiction Group, and CHOICES Education Group, offers comprehensive on-demand education on the treatment and management of opioid use disorder and other substance use disorders that meets the eight-hour requirement for DEA-registered physicians and physician assistants, outlined in the Consolidated Appropriations Act of 2023. This activity is approved for AMA PRA Category 1 CreditTM.

Opioid Prescribing Regulations Post-COVID-19 Public Health Emergency WSMA members only—sign-in required
This on-demand training, available exclusively to WSMA members, meets the state's one-time, one-hour continuing medical education on opioid prescribing requirement for MDs, DOs, and PAs. This activity has been approved for AMA PRA Category 1 CreditTM.

Pain management rule requirements checklist

WSMA Pain Management Rule Requirements Checklist - updated February 2020
Use this updated document to build prompts into your electronic health record (e.g., Epic dot phrase) or simply use as a checklist to help you successfully incorporate opioid prescribing rule requirements into your practice workflow.

Other Prescribing Resources

DOH handouts to meet state requirement for patient education

The Department of Health offers patient handouts (look under Public/Patient) for all categories of pain patients (chronic, surgical, acute, and subacute) to satisfy a new state requirement for prescribers to inform patients of the risks, safe storage, and safe disposal of prescription opioids.

Connecting to the prescription monitoring program

Access prescription drug monitoring program data through the state Health Information Exchange or directly through the state's PMP vendor, Bamboo Health: PMP Gateway. PMP Gateway integrates multi-state prescription drug monitoring program intelligence into existing clinical workflows, improving access and saving time for care team members.

PMP Gateway delivers full transparency into prescription drug monitoring program data and analytics by integrating directly into the workflows of 500+ clinical systems including electronic health records, pharmacy management systems and health information exchanges—saving an average of four minutes per patient search, making it easier to comply and improve patient safety.

Learn more about the benefits of PMP Gateway and its impact by reviewing the webpage most applicable to you, below:

More resources

Washington State Department of Health opioid prescribing webpage

Washington Agency Medical Directors' Group prescribing guidelines and resources

CDC Clinical Practice Guideline for Prescribing Opioids for Pain, 2022

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